Home / Agencies / Treasury / 2025-23292
Final Rule

Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions

Agency
Treasury
Document Number
2025-23292
Published
December 18, 2025
Effective Date
December 17, 2025

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.

Federal Register Source

This document is published by the Office of the Federal Register, National Archives and Records Administration. Access the full regulatory text, preamble, and docket comments below.

View Full Text on FederalRegister.gov →

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Frequently Asked Questions

What is the 2025-23292 Federal Register document?
Document 2025-23292 is a Final Rule published by the Department of the Treasury in the Federal Register on December 18, 2025, with an effective date of December 17, 2025. 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. View the original at https://www.federalregister.gov/documents/2025/12/18/2025-23292/base-erosion-and-anti-abuse-tax-rules-for-qualified-derivative-payments-on-securities-lending.
Is document 2025-23292 an economically significant rule?
No. Document 2025-23292 is not classified as economically significant under Executive Order 12866. Economically significant rules require OIRA review and are estimated to have impacts of $100 million or more per year.

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