{"abstract":"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.","action":"Notice of proposed rulemaking.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2024/08/07/2024-16665.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26},{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"89 FR 64750","comment_url":"http://www.regulations.gov/commenton/IRS-2024-0035-0001","comments_close_on":"2024-10-07","correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by October 7, 2024.","disposition_notes":null,"docket_ids":["REG-105128-23"],"dockets":[{"supporting_documents":[],"agency_name":"IRS","documents":[{"comment_count":21,"comment_start_date":"2024-08-07","updated_at":"2025-02-03T21:55:54.034-05:00","comment_url":"https://www.regulations.gov/commenton/IRS-2024-0035-0001","allow_late_comments":true,"id":"IRS-2024-0035-0001","comment_end_date":"2024-10-08","regulations_dot_gov_open_for_comment":true}],"supporting_documents_count":0,"id":"IRS-2024-0035","title":"Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments (REG-105128-23)"}],"document_number":"2024-16665","effective_on":null,"end_page":64778,"executive_order_notes":null,"executive_order_number":null,"explanation":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2024/08/07/2024-16665.xml","html_url":"https://www.federalregister.gov/documents/2024/08/07/2024-16665/rules-regarding-dual-consolidated-losses-and-the-treatment-of-certain-disregarded-payments","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2024-16665?publication_date=2024-08-07","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2024-08-07/2024-16665/mods.xml","not_received_for_publication":null,"page_length":29,"page_views":{"count":2404,"last_updated":"2026-04-04 14:15:05 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2024-08-07/pdf/2024-16665.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2024-16665.pdf?1722948312","publication_date":"2024-08-07","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2024/08/07/2024-16665.txt","regulation_id_number_info":{"1545-BQ72":{"issue":"202410","html_url":"https://www.federalregister.gov/regulations/1545-BQ72/certain-dual-consolidated-loss-rules","title":"Certain Dual Consolidated Loss Rules","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202410&RIN=1545-BQ72&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BQ72"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BQ72/certain-dual-consolidated-loss-rules","title":"Certain Dual Consolidated Loss Rules"},"comments_count":21,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2024-0035","supporting_documents_count":0,"docket_id":"IRS-2024-0035","document_id":"IRS-2024-0035-0001","regulation_id_number":"1545-BQ72","title":"Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments (REG-105128-23)","checked_regulationsdotgov_at":"2025-02-05T01:55:03Z"},"regulations_dot_gov_url":"http://www.regulations.gov/commenton/IRS-2024-0035-0001","significant":false,"signing_date":null,"start_page":64750,"subtype":null,"title":"Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments","toc_doc":"Dual Consolidated Losses and the Treatment of Certain Disregarded Payments","toc_subject":null,"topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":89}