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United States | Proposed BEAT regulations would provide favorable guidance on qualified derivative payments in securities lending transactions

|Tax Alerts, Asset Management, Banking &a ...|United States
United States

  • The proposed regulations would exclude mark-to-market gain or loss on a securities loan from "base erosion payments."
  • The proposed regulations provide an alternative method to determine the recipient of a substitute payment on a securities loan.
  • The QDP "good faith reporting period" has been extended to tax years beginning on or after 1 January 2027, consistent with Notice 2024-43.
 

In proposed regulations (REG-107895-24; the Proposed Regulations) released 10 January 2025, under IRC Section 59…

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