Notice 2025-75, 2025-77, 2025-78: International tax law provisions under the One, Big Beautiful Bill

Notice 2025-75 announces that the Department of the Treasury and the Internal Revenue Service intend to issue proposed regulations regarding the transition rule for dividends (the “transition rule”) in section 70354(c)(2) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act. The transition rule modifies the application of section 951(a)(2)(B) of the Internal Revenue Code for certain taxable years of foreign corporations beginning before January 1, 2026.

Notice 2025-77 describes proposed regulations that Treasury and the IRS intend to issue under section 70312 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), providing guidance on the effective date and application of section 960(d)(4) of the Internal Revenue Code.

Notice 2025-78 announces that the Department of the Treasury and the Internal Revenue Service intend to issue regulations regarding the new rules for calculating DEI. This notice primarily addresses the meanings of intangible property, “any other property of a type,” and sale or other disposition for section 250.

Notice 2025-75, Notice 2025-77, and Notice 2025-78 will be in IRB: 2025-52, dated: December 22, 2025.

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