Data / Federal rules / 2025-23292
Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
The Internal Revenue Service published this final rule in the Federal Register on December 18, 2025. It took effect on December 17, 2025.
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What the agency says
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.
Key facts
- Document number
- 2025-23292
- Type
- Final rule
- Action
- Final rule
- Agency
- Treasury Department; Internal Revenue Service
- Published
- December 18, 2025
- Takes effect
- December 17, 2025
- Dates
- Effective date: The final regulations are effective December 17, 2025.
- Docket
- TD 10041
- Regulation ID (RIN)
- 1545-BR20
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 6
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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.