Data / Federal rules / 2025-00318
Rules Regarding Certain Disregarded Payments and Dual Consolidated Losses
The Internal Revenue Service published this final rule in the Federal Register on January 14, 2025. It took effect on January 10, 2025.
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What the agency says
This document contains final regulations regarding certain disregarded payments that give rise to deductions for foreign tax purposes and avoid the application of the dual consolidated loss ("DCL") rules. The final regulations affect domestic corporate owners that make or receive such payments. This document also announces additional transition relief for the application of the DCL rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax.
Key facts
- Document number
- 2025-00318
- Type
- Final rule
- Action
- Final rule
- Agency
- Treasury Department; Internal Revenue Service
- Published
- January 14, 2025
- Takes effect
- January 10, 2025
- Dates
- Effective date: These regulations are effective on January 10, 2025.
- Docket
- TD 10026
- Regulation ID (RIN)
- 1545-BQ72
- Code of Federal Regulations
- 26 CFR 1; 26 CFR 301
- Topics
- Employment taxes; Estate taxes; Excise taxes; Gift taxes; Income taxes; Penalties; Reporting and recordkeeping requirements
- Pages
- 19
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Everything from the Internal Revenue Service · Rules on employment taxes · Rules on estate taxes · Rules on excise taxes · Published in January 2025
Read from the Federal Register API, last updated 2026-10-24. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.