SECTION 5. APPLICABILITY

DATES AND RELIANCE

The forthcoming proposed section 898 regulations would apply to taxable years of specified foreign corporations beginning after November 30, 2025. A taxpayer may rely on the rules described in section 3 of this notice for foreign taxes paid or accrued in taxable years of specified foreign corporations beginning after November 30, 2025, and ending before the forthcoming proposed section 898 regulations are published in the Federal Register, provided the taxpayer applies the rules in section 3 of this notice in their entirety and in a consistent manner for the first required year and succeeding taxable year of a specified foreign corporation.

The forthcoming proposed section 987 regulations would apply to taxable years beginning after December 31, 2024, and ending on or after November 25, 2025. A taxpayer may rely on the rules described in section 4 of this notice before the forthcoming proposed section 987 regulations are published in the Federal Register for a taxable year to which the section 987 regulations apply, provided the taxpayer applies the rules described in section 4 of this notice in their entirety and in a consistent manner with respect to each section 987 QBU, original deferral QBU, and outbound loss QBU for that taxable year and each subsequent taxable year.

December 15, 2025 844 Bulletin No. 2025–51