2025-20264Notice

IRS Tackles Tricky Debt Discounts and Cheat-Proof Payments

Published Date: 11/19/2025

Notice

Summary

The IRS wants your thoughts on how it collects info about certain types of loans and payments, especially those with special discounts or tricky rules to stop cheating. If you deal with these debt instruments, your feedback can help make reporting easier and clearer. Hurry—comments are due by January 20, 2026, so don’t miss your chance to shape the rules and possibly save time and money!

Analyzed Economic Effects

2 provisions identified: 0 benefits, 2 costs, 0 mixed.

Tax rules for contingent-payment debt

The regulation (TD 8674) provides rules, definitions, and reporting and recordkeeping requirements for debt instruments with original issue discount (OID) that make contingent payments and for debt instruments integrated with related hedges. These rules apply to businesses, individuals, and state, local, or tribal governments that deal with such debt instruments.

Estimated information-collection burden

The IRS estimates 180,000 respondents for this information collection, at an average of 29 minutes per respondent, for a total estimated 89,000 annual burden hours. The agency is extending a currently approved collection (OMB Number 1545-1450) and is soliciting comments by January 20, 2026.

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Key Dates

Effective Date
Published Date
Comments Due
11/17/2025
11/19/2025
1/20/2026

Department and Agencies

Department
Independent Agency
Agency
Treasury Department
Internal Revenue Service
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