The U.S. IRS has issued Notice 2025-44 on proposed regulations withdrawing the disregarded payment loss ("DPL") rules finalized on 14 January 2025, and extending the transition relief initially announced in Notice 2023-80 with respect to the interaction of the dual consolidated loss ("DCL") rules and the model rules published by the OECD/G20 Inclusive Framework on BEPS (the "GloBE Model Rules").
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Notice 2025-44: Treasury and the IRS intend to issue proposed regulations withdrawing th…