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 applies to DCLs incurred in tax years ending on or after 6 August 2024, and to DPLs in tax years beginning on or after 1 January 2026.Treasury and the IRS have extended transitional relief regarding the interaction of...