Notice 2025-63, page 709.

This explains that proposed regulations will be issued to provide a rule for determining the source of certain borrow fees paid with respect to securities lending transactions and sale-repurchase transactions. These fees would be sourced based on the residence of the recipient.

Finding Lists begin on page ii.

REG-109742-25, page 712. These proposed regulations would modify the determination of whether a qualified investment entity (QIE) is domestically controlled by removing a rule in previously promulgated final regulations that looks to the shareholders of certain domestic corporations in determining whether foreign persons hold directly or indirectly stock in a QIE.