17 December 2025

Treasury and IRS finalize regulations on mark-to-market exception for qualified derivative payments

The Treasury Department and IRS on December 17, 2025, issued final regulations (TD 10041) under IRC Section 59A for determining and reporting qualified derivative payments (QDPs) on securities lending transactions. The final regulations adopt the January 2025 proposed regulations (Tax Alert 2025-0378) with some clarifying amendments. A Tax Alert is forthcoming.

Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2025-2536