The U.S. IRS issued Notice 2025-72 on 25 November 2025, announcing that the Treasury Department and the IRS intend to issue proposed regulations under section 70352 of the "One Big Beautiful Bill Act" (OBBBA), which repealed the one-month deferral election under section 898(c)(2) for a specified foreign corporation’s first tax year beginning after 30 November 2025. With the repeal of the elect…