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United States | Final regulations on DPL rules retain proposed regulations' framework but include several modifications

|Tax Alerts, Legislation & Policy, Gl ...|United States
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…

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