Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
other · IRS · Rule · Published 2025-12-18 · Effective 2025-12-17 · 90 FR 59046
Document
Document number
2025-23292
Federal Register citation
90 FR 59046
CFR reference
26 CFR 1
Type
Rule
Action
Final rule.
Category
other
Sub-agency
IRS
Publication date
2025-12-18
Effective date
2025-12-17
Treasury docket
TD 10041
Abstract
This document contains final regulations regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The final regulations relate to how qualified derivative payments with respect to securities lending transactions are determined and reported. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties.