Notice 2025-72, page 840.

This notice describes proposed regulations that Treasury and the IRS intend to issue under section 70352(c)(1)(C) of Public Law 119-21, 139. Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), providing for the allocation of foreign taxes of foreign corporations affected by the repeal of section 898(c)(2). This notice also announces that Treasury and the IRS intend to issue proposed regulations under section 987 that would modify the election to recognize pretransition section 987 gain or loss ratably over the transition period pursuant to §1.987-10(e)(5)(ii)(A).