Finance et marchés · 08/11/20241 min de lecture
Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments; Hearing
Traduction automatique locale · Langue originale de la source
Résumé
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.