Federal Register (IRS) · Dec 18, 2025
Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
Tax Brief summary and classification of the original reporting.
Bottom Line
💡 Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Se.... General industry update.
Summary
[Rule] 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.
Classification
Applies To
Affected Groups
Individual return preparers, C-Corp practitioners, International tax practitioners
Related Topics
Original Source
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