26 November 2025 IRS releases guidance on OBBBA repeal of 'one-month deferral election' The IRS on 25 November released Notice 2025-72, which addresses the repeal of the "one-month deferral election" in IRC Section 898(c)(2) by the "One Big Beautiful Bill" Act (OBBBA). The notice indicates that forthcoming regulations would allocate certain foreign income taxes that accrue during the mandatory, one-month "short year" caused by the repeal of the one-month deferral election. The notice also indicates that future guidance would modify the IRC Section 987 loss transition rule to require amortization of pre-transition losses over 120 months (rather than 10 tax years). A Tax Alert on Notice 2025-72 is forthcoming. Document ID: 2025-2381 |
