United States | Final regulations on DPL rules retain proposed regulations' framework but include several modifications
|Tax Alerts, Legislation & Policy, Gl ...|United States
The final regulations finalize, with modifications, the disregarded payment loss (DPL) rules introduced by the proposed regulations in August 2024, as well as an anti-avoidance rule applicable to both dual consolidated losses (DCLs) and DPLs.
The DPL rules apply to tax years beginning on or after 1 January 2026 — a significant delay from their proposed effective date — while the anti-avoidance rule applies to DCLs incurred in tax years ending on or after 6 August 2024, and to DPLs in tax years be…
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