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. --- SUMMARY: This document contains proposed regulations that address certain issues arising under the dual consolidated loss rules, including the effect of intercompany transactions and items arising from stock ownership in calculating a dual consolidated loss. The proposed regulations also address the application of the dual consolidated...