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Notice 2025-6

SECTION 3. REQUEST FOR

Internal Revenue Bulletin 2025-8 · 2026-10-03 edition · updated 2026-10-04 · United States

COMMENTS

The Treasury Department and the IRS request comments regarding any consequences or interactions that would result if the characterization rules currently contained in §§1.861-18 and 1.861-19, as amended and added, respectively, by the 2025 final regulations, were to apply to all provisions of the Code. Comments are requested on any specific areas that would be affected, with examples where appropriate. Comments are also requested on any guidance that would be needed, including what approach such guidance should take. In addition to general comments, the Treasury Department and the IRS request comments, with examples,

regarding the desirability and effects, if any, of applying the characterization rules currently contained in §§1.861-18 and 1.861-19 on the rules in the following areas, including whether further guidance in these areas would be necessary and, if so, what the approach of the guidance should be:

  • Section 167(f)

  • Section 168(g)(1)(B)

  • Section 178

  • Section 197

  • Section 263

  • Section 451

  • Sections 263A and 471

  • Sections 856 through 859

  • Sections 1001 and 1011

  • Sections 1221 and 1222

  • Section 1241

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