The U.S. IRS and Treasury have issued a Notice of proposed rulemaking on Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, including in relation to the Pillar 2 GloBE rules. The notice was published in the Federal Register on 7 August 2024, with comments due by 7 October 2024.

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SUMMARY:

This document contains proposed regulations that address ce…