Data / Federal rules / 2024-16665
Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments
The Internal Revenue Service published this proposed rule in the Federal Register on August 7, 2024. Comments closed on October 7, 2024.
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What the agency says
This document contains proposed regulations that address certain issues arising under the dual consolidated loss rules, including the effect of intercompany transactions and items arising from stock ownership in calculating a dual consolidated loss. The proposed regulations also address the application of the dual consolidated loss rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax, including exceptions to the application of the dual consolidated loss rules with respect to such foreign taxes. Finally, the proposed regulations include rules regarding certain disregarded payments that give rise to losses for foreign tax purposes.
Key facts
- Document number
- 2024-16665
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- August 7, 2024
- Comments due
- October 7, 2024
- Dates
- Written or electronic comments and requests for a public hearing must be received by October 7, 2024.
- Docket
- REG-105128-23
- 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
- 29
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Read from the Federal Register API, last updated 2026-10-23. 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.