IRS Addresses ‘Mirror Legislation’ Concern for Global Tax, Losses

Administrative guidance released by the OECD on the global minimum tax still gives companies the choice of where to use a loss in their corporate structure, an IRS official said Friday.

Tax practitioners have raised concerns that administrative guidance published on how to use a safe harbor under the 15% global minimum tax could prohibit companies from choosing where they’d like to use their loss in their corporate structures.

Multinational companies incur losses or expenses that can be used to offset income from other places in their structures. The US has dual consolidated loss rules meant to prevent a “double-dipping” ...