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Notice 2025-46

SECTION 6. LIMITATIONS ON

Internal Revenue Bulletin 2025-43 · 2026-10-03 edition · updated 2026-10-04 · United States

ACQUIRED FSNOLS AND CERTAIN BUILT-IN ITEMS

.01 Purpose . The Treasury Department and the IRS anticipate that the forthcoming proposed regulations will revise proposed § 1.56A-23 consistent with the interim guidance provided in section 6.02 of this notice for determining the amount of FSNOLs that are available to reduce AFSI, which is intended to reduce compliance burdens and costs associated with applying proposed § 1.56A-23 in response to comments.

.02 Adjustments to AFSI . In computing the amount of FSNOLs that are available to reduce AFSI, a CAMT entity need not apply the limitations in proposed § 1.56A-23(e) and (f).

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