Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments; Correction

摘要

This document contains corrections to the proposed regulations (REG-105128-23), published in the Federal Register on August 7, 2024. The proposed regulations concern certain issues arising under the dual consolidated loss rules and the application of those rules to certain foreign taxes. The proposed regulations also include rules regarding certain disregarded payments that give rise to losses for foreign tax purposes.