The US Internal Revenue Service (IRS) Associate Chief Counsel's Office (International) has published a Chief Counsel Advice that addresses reasonable cause requests with respect to dual consolidated losses that are subject to Section 1503(d) of the US Internal Revenue Code (IRC) and the Treasury Regulations thereunder. The dual consolidated loss rules are intended to prevent dual resident corporations from using losses to offset both US and foreign taxable income. The IRS Chief Counsel Advice is entitled "Dual Consolidated Losses: Reasonable Cause Requests Relating to Periods Where Assessment of Tax Under Section 6501(a) Is Not Permitted." It is designated AM 2008-01...