04 December 2025 Treasury and IRS announce intent to issue proposed regulations implementing OBBBA's international tax provisions On December 4, 2025, the Treasury Department and IRS released three notices announcing the intent to release proposed regulations related to changes made by the "One Big Beautiful Bill Act" (OBBBA): - Notice 2025-75 addresses the transition rule for dividends under IRC Section 951(a)
- Notice 2025-77 addresses the effective date and application of IRC Section 960(d)(4), which disallows a foreign tax credit for 10% of any foreign income taxes paid or accrued (or deemed paid) with respect to any amount excluded from gross income under IRC Section 959(a) by reason of an inclusion in gross income under IRC Section 951A(a)
- Notice 2025-78 addresses the new rules for calculating "Foreign Derived Deduction Eligible Income" (FDDEI), and primarily addresses the meanings of intangible property, "any other property of a type," and sale or other disposition for purposes of IRC Section 250
A Tax Alert is forthcoming. | * * * * * * * * * * | | Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor |
Document ID: 2025-2425 |
