IRSFinal Rule
Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
Finance & Banking
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Summary
This IRS rule prevents large corporations from using complex financial tricks involving securities lending (borrowing stocks) to dodge federal taxes. It closes a loophole where companies could reduce their tax bills through certain derivative payments, ensuring they pay their fair share.
Key Points
- 1Large corporations can no longer use certain derivative payments from securities lending deals to artificially lower their taxable income
- 2The rule targets sophisticated financial strategies that were previously used to shift profits away from U.S. taxation
- 3Companies engaged in securities lending will need to track and report these payments differently to the IRS
- 4This is part of broader anti-abuse rules designed to prevent tax avoidance by large businesses
- 5The rule applies mainly to multinational corporations and large financial firms, not small businesses or individuals
Key Dates
Published
December 18, 2025
This summary is for informational purposes only. It may not capture all nuances of the regulation. Always refer to the official text for authoritative information.
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