Data / Federal rules / 2025-00186
Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
The Internal Revenue Service published this proposed rule in the Federal Register on January 14, 2025. Comments closed on April 14, 2025.
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What the agency says
This document contains proposed 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 proposed regulations relate to how qualified derivative payments with respect to securities lending transactions are determined and reported. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.
Key facts
- Document number
- 2025-00186
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- January 14, 2025
- Comments due
- April 14, 2025
- Dates
- Written or electronic comments and requests for a public hearing must be received by April 14, 2025.
- Docket
- REG-107895-24
- Regulation ID (RIN)
- 1545-BR20
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 8
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Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.