On October 20, TEI submitted comments on Notice 2025-44, which announced the forthcoming withdrawal of final regulations concerning disregarded payments losses and related changes to the dual consolidated loss (DCL) rules, among other things.
The letter included comments on the definition of foreign use, the DCL rules’ treatment of disregarded payments, the interaction of the DCL regime and top-up taxes, and income arising from the stock of foreign corporations.
The TEI Tax Reform Task Force, whose chair is Andreia Verissimo, prepared the comments in coordination with TEI Tax Counsel Kelly Madigan. Read the comments here.
