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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