SECTION 6. REQUEST FOR

COMMENTS

The Treasury Department and the IRS request comments on the rules described in sections 3 and 4 of this notice. The Treasury Department and the IRS specifically request comments on whether the allocation rule provided in section 3.05 of this notice should apply to any foreign taxes other than specified foreign income taxes, such as an affected corporation’s distributive share of foreign income taxes paid or accrued by a partnership that is required to change its taxable year because of the change in taxable year of the affected corporation. The Treasury Department and the IRS also request comments on whether there are other rules that, similar to the amortization of pretransition gain or loss described in section 2.04 of this notice, apply over multiple years and may warrant guidance to address their application in light of short taxable years resulting from the repeal of section 898(c)(2).

Written comments should be submitted by January 24, 2026. The subject line for comments should include a reference to Notice 2025-72. Comments may be submitted electronically via the Federal eRulemaking Portal at https://www. regulations.gov (type IRS-2025-0433 in the search field on the regulations.gov homepage to find this notice and submit comments). Written comments may be mailed to Internal Revenue Service, CC:PA:01:PR (Notice 2025-72), Room 5503, P.O. Box 7604, Ben Franklin Station, Washington, D.C., 20044. All commenters are strongly encouraged to submit comments electronically.

The Treasury Department and the IRS will publish for public availability any comment submitted electronically and on paper to its public docket on regulations. gov.