SECTION 11. REQUEST FOR

COMMENTS

.01 Comments regarding guidance provided in section 5 of this notice . The Treasury Department and the IRS request comments on the interim guidance set forth in section 5 of this notice.

(1) Interim AFSI adjustments for certain fair value items . The Treasury Department and the IRS continue to study whether the interim guidance described in this section 5 creates unintended results, including mismatches or distortions between AFSI and regular taxable income, and request comments identifying those unintended results. Commenters are also encouraged to specify the issues on which additional guidance is needed for fair value items.

(2) Coordination with proposed § 1.56A-22 . The Treasury Department and the IRS request comments on how the rules in proposed § 1.56A-22(c) and proposed § 1.56A-22(d) and the guidance described in section 5.02 through section 5.07 of this notice should be coordinated. .02 Procedures for Submitting Com- ments .

(1) Deadline . Written comments should be submitted by December 1, 2025. Consideration will also be given to any written comment submitted after December 1, 2025, although such comments may not be considered in the development of the forthcoming proposed regulations if such consideration would delay the publication of the forthcoming proposed regulations.

(2) Form and manner . The subject line for the comments should include a reference to Notice 2025-49. All commenters are strongly encouraged to submit comments electronically. Comments may be submitted in one of two ways:

(a) electronically via the Federal eRulemaking Portal at https://www.regulations.gov (type IRS-2025-0202 in the search field on the https://www.regulations.gov homepage to find this notice and submit comments); or

(b) by mail to: Internal Revenue Service, CC:PA:01:PR (Notice 2025-49), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C., 20044.

(3) Publication of comments . The Treasury Department and the IRS will publish for public availability any comment sub

October 27, 2025 644 Bulletin No. 2025–44

mitted electronically and on paper to the IRS’s public docket on https://www.regulations.gov.