IRS Prop. Reg.: Dual Consolidated Losses and the Treatment of Certain Disregarded Payments (IRC §1503)

The IRS released proposed regulations addressing certain issues arising under the dual consolidated loss (DCL) rules, including: (1) the effect of intercompany transactions and items arising from stock ownership in calculating a DCL; (2) the application of the DCL rules to certain foreign taxes intended to ensure multinational enterprises pay a minimum level of tax (including exceptions to the application of the DCL rules with respect to those foreign taxes); and (3) rules regarding certain disregarded payments that give rise to losses for foreign tax purposes. Written or electronic comments and requests for a public hearing must be received by ...