The US Internal Revenue Service (IRS) has released a Chief Counsel Advice regarding termination of an election under Section 1504(d) of the US Internal Revenue Code (IRC) dealing with dual consolidated losses. The Chief Counsel Advice is entitled Section 1503(d) Issues Upon Termination of Section 1504(d) Election. It was issued by the IRS Large and Midsize Business Division (LSMB) and is designated ILM 200810023, dated 19 November 2007, and was released 7 March 2008. The dual consolidated loss (DCL) rules of IRC Section 1504 are intended to prevent dual resident corporations from using losses to offset both US and foreign...