The proposed regulations would exclude mark-to-market gain or loss on a securities loan from "base erosion payments."The proposed regulations provide an alternative method to determine the recipient of a substitute payment on a securities loan.The QDP "good faith reporting period" has been extended to tax years beginning on or after 1 January 2027, consistent with Notice 2024-43. In proposed regulations (REG-107895-24; the Proposed Regulations) released 10 January 2025, under IRC Section 59A, the IRS and Treasury Department outlined how to determine and report qualified derivative payments (QDPs) on securities lending transactions.BackgroundIn addition to any other income tax, an applicable taxpayer for...