The IRS on Friday finalized regulations that limit the use of deductions by multinational companies when certain kinds of entities make payments to a US corporation and when a US corporation includes a loss in their global minimum tax calculations.
The final regulations (TD 10026, RIN:1545-BQ72) retain many of the changes that were made to the dual consolidated loss and disregarded payment loss regulations proposed in August, a fact that upsets tax practitioners.
“It’s quite evident that they didn’t fully review and consider taxpayer comments,” said Anne Gordon, vice president of international tax policy at the National Foreign ...
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