US Treasury and IRS Finalize BEAT Rules on Qualified Derivative Payments from Securities Lending Transactions

The U.S. Treasury Department and the Internal Revenue Service (IRS) have released final regulations on 17 December 2025 (published in the Federal Register on 18 December 2025) setting out how qualified derivative payments (QDPs) are determined and reported for securities lending transactions for purposes of the base erosion and anti-abuse tax (BEAT) under IRC § 59A, and related reporting rules …
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