Treasury Plans to Withdraw Disregarded Payment Loss Rules (2)

The IRS and the Treasury Department will propose regulations to withdraw disregarded payment loss rules finished in the last month of the Biden administration.

The agencies said in Notice 2025-44, issued Wednesday, that their proposal will also extend the temporary relief provided to corporate taxpayers who are subject to final regulations detailing how the 15% global minimum tax rules and the US’ dual consolidated loss rules mesh.

In January, the Treasury Department finalized regulations that eliminated a practice that companies have wanted to preserve: recording foreign losses and overseas tax deductions on DPLs without having to count the payment on ...