On October 7, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations addressing dual consolidated losses ("DCL") and new disregarded payment loss rules. TEI's comments focused on the interaction of the DCL rules and the OECD Pillar Two regimes, "triggering events" under the DCL rules, and the newly created DPL regime, among other things. TEI's comments were prepared under the aegis of its Tax Reform Task Force, whose Chair is Andreia Verissimo. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.
Committee