Notice2025-20264

Agency Information Collection Activities; Comment Request on Debt Instruments With Original Issue Discount (OID); Contingent Payments; Anti-Abuse Rule

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
November 19, 2025

Issuing agencies

Treasury DepartmentInternal Revenue Service

Abstract

In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice. Currently, the IRS is soliciting comments concerning the burden of information reporting for debt instruments with original issue discount; contingent payments; anti-abuse rule.

Full Text

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<title>Federal Register, Volume 90 Issue 221 (Wednesday, November 19, 2025)</title>
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[Federal Register Volume 90, Number 221 (Wednesday, November 19, 2025)]
[Notices]
[Pages 52163-52164]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-20264]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Agency Information Collection Activities; Comment Request on Debt 
Instruments With Original Issue Discount (OID); Contingent Payments; 
Anti-Abuse Rule

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: In accordance with the Paperwork Reduction Act of 1995, the 
IRS is inviting comments on the information collection request outlined 
in this notice. Currently, the IRS is soliciting comments concerning 
the burden of information reporting for debt instruments with original 
issue discount; contingent payments; anti-abuse rule.

DATES: Written comments should be received on or before January 20, 
2026 to be assured of consideration.

ADDRESSES: Direct all written comments to Andr[eacute]s Garcia, 
Internal Revenue Service, Room 6526, 1111 Constitution Avenue NW, 
Washington, DC 20224, or

[[Page 52164]]

by email to <a href="/cdn-cgi/l/email-protection#0c7c7e6d226f6361616962787f4c657e7f226b637a"><span class="__cf_email__" data-cfemail="443436256a272b2929212a3037042d36376a232b32">[email&#160;protected]</span></a>. Please include, ``OMB Number: 1545-
1450--Public Comment Request Notice'' in the Subject line.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the form and instructions should be directed to Ronald J. 
Durbala, at (202) 317-5746, at Internal Revenue Service, Room 6526, 
1111 Constitution Avenue NW, Washington, DC 20224, or through the 
internet at <a href="/cdn-cgi/l/email-protection#6230280d1107120a4c26171000030e03220b10114c050d14"><span class="__cf_email__" data-cfemail="085a42677b6d7860264c7d7a6a69646948617a7b266f677e">[email&#160;protected]</span></a>.

SUPPLEMENTARY INFORMATION: The IRS, in accordance with the Paperwork 
Reduction Act of 1995 (PRA) (44 U.S.C. 3506(c)(2)(A)), provides the 
public and Federal agencies with an opportunity to comment on proposed, 
revised, and continuing collections of information. This helps the IRS 
assess the impact and minimize the burden of its information collection 
requirements. Comments submitted in response to this notice will be 
summarized and/or included in the request for OMB approval. All 
comments will become a matter of public record, and viewable on 
relevant websites. For this reason, please do not include in your 
comments information of a confidential nature, such as sensitive 
personal information.
    Comments are invited on: (a) Whether the collection of information 
is necessary for the proper performance of the functions of the agency, 
including whether the information shall have practical utility; (b) the 
accuracy of the agency's estimate of the burden of the collection of 
information; (c) ways to enhance the quality, utility, and clarity of 
the information to be collected; (d) ways to minimize the burden of the 
collection of information on respondents, including through the use of 
automated collection techniques or other forms of information 
technology; and (e) estimates of capital or start-up costs and costs of 
operation, maintenance, and purchase of services to provide 
information.
    Title: Debt Instruments with OID; Contingent Payments; Anti-Abuse 
Rule.
    OMB Number: 1545-1450.
    Regulation Project Number: TD 8674.
    Abstract: This regulation relates to the tax treatment of debt 
instruments that provide for one or more contingent payments. The 
regulation also treats a debt instrument and a related hedge as an 
integrated transaction. The regulation provides general rules, 
definitions, and reporting and recordkeeping requirements for 
contingent payment debt instruments and for integrated debt 
instruments.
    Current Actions: There is no change to the burden previously 
approved by OMB.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Business or other for-profit organizations, 
individuals, and state, local, or tribal governments.
    Estimated Number of Respondents: 180,000.
    Estimated Time per Respondent: 29 minutes.
    Estimated Total Annual Burden Hours: 89,000.

    Approved: November 17, 2025.
Ronald J. Durbala,
IRS Tax Analyst.
[FR Doc. 2025-20264 Filed 11-18-25; 8:45 am]
BILLING CODE 4830-01-P


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Indexed from Federal Register on November 19, 2025.

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