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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

The document on federalregister.gov PDF

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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.