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 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 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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