Data / Federal rules / 2024-26030
Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments; Hearing
The Internal Revenue Service published this proposed rule in the Federal Register on November 8, 2024.
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What the agency says
This document provides a notice of public hearing on the proposed rule (REG-105128-23) that was published in the Federal Register on Wednesday, August 7, 2024. The proposed regulations relate to 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
- 2024-26030
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking; public hearing
- Agency
- Treasury Department; Internal Revenue Service
- Published
- November 8, 2024
- Dates
- The public hearing is scheduled to be held on November 22, 2024, at 10:00 a.m. Eastern Time (ET). The IRS must receive speakers' outlines of topics to be discussed at the public hearing by November 14, 2024. If no outlines are received by November 14, 2024, the public hearing will be cancelled.
- Docket
- REG-105128-23
- Regulation ID (RIN)
- 1545-BQ72
- Code of Federal Regulations
- 26 CFR 1; 26 CFR 301
- Pages
- 1
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Everything from the Internal Revenue Service · Published in November 2024
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.