Proposed Rule2024-26030
Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments; Hearing
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
November 8, 2024
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document provides a notice of public hearing on the proposed rule (REG-105128-23) that was published in the Federal Register on Wednesday, August 7, 2024. The proposed regulations relate to 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 loss rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax, including exceptions to the application of the dual consolidated loss rules with respect to such foreign taxes. Finally, the proposed regulations include rules regarding certain disregarded payments that give rise to losses for foreign tax purposes.
Full Text
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<title>Federal Register, Volume 89 Issue 217 (Friday, November 8, 2024)</title>
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[Federal Register Volume 89, Number 217 (Friday, November 8, 2024)]
[Proposed Rules]
[Page 88686]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-26030]
[[Page 88686]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 301
[REG-105128-23]
RIN 1545-BQ72
Rules Regarding Dual Consolidated Losses and the Treatment of
Certain Disregarded Payments; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; public hearing.
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SUMMARY: This document provides a notice of public hearing on the
proposed rule (REG-105128-23) that was published in the Federal
Register on Wednesday, August 7, 2024. The proposed regulations relate
to 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 loss rules to certain foreign taxes that are intended to
ensure that multinational enterprises pay a minimum level of tax,
including exceptions to the application of the dual consolidated loss
rules with respect to such foreign taxes. Finally, the proposed
regulations include rules regarding certain disregarded payments that
give rise to losses for foreign tax purposes.
DATES: The public hearing is scheduled to be held on November 22, 2024,
at 10:00 a.m. Eastern Time (ET). The IRS must receive speakers'
outlines of topics to be discussed at the public hearing by November
14, 2024. If no outlines are received by November 14, 2024, the public
hearing will be cancelled.
ADDRESSES: The public hearing is being held in the Auditorium, at the
Internal Revenue Service Building, 1111 Constitution Avenue NW,
Washington, DC. Due to security procedures, visitors must enter at the
Constitution Avenue entrance. In addition, all visitors must present a
valid photo identification to enter the building. Because of access
restrictions, visitors will not be admitted beyond the immediate
entrance area more than 30 minutes before the hearing starts.
Participants may alternatively testify or attend the hearing by
telephone.
Send an outline of topic submissions electronically via the Federal
eRulemaking Portal at <a href="http://www.regulations.gov">www.regulations.gov</a> (indicate IRS and REG-105128-
23). Send paper submissions to CC:PA:01:PR (REG-105128-23), Room 5205,
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Andrew L. Wigmore at (202) 317-5443; concerning the submission of
requests to testify, the hearing, the access code to attend the hearing
by phone, or to be placed on the building access list to attend the
public hearing, contact the Publications and Regulations Section at
(202) 317-6901 (not a toll-free number), or by email at
<a href="/cdn-cgi/l/email-protection#75050017191c161d1014071c1b1206351c07065b121a03"><span class="__cf_email__" data-cfemail="d9a9acbbb5b0bab1bcb8abb0b7beaa99b0abaaf7beb6af">[email protected]</span></a> (preferred).
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking (REG-105128-23) that was published in the
Federal Register on Wednesday, August 7, 2024 (89 FR 64750).
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments at the hearing must submit an outline of
the topics to be discussed and the time to be devoted to each topic by
November 14, 2024.
A period of 10 minutes will be allotted to each person for making
comments. An agenda showing the scheduling of the speakers will be
prepared after the deadline for receiving outlines has passed. Copies
of the agenda will be available free of charge at the hearing and via
the Federal eRulemaking Portal (<a href="https://www.Regulations.gov">https://www.Regulations.gov</a>) under the
title of Supporting & Related Material. If no outline of the topics to
be discussed at the hearing is received by November 14, 2024, the
public hearing will be cancelled. If the public hearing is cancelled, a
notice of cancellation of the public hearing will be published in the
Federal Register.
Individuals who want to testify in person at the public hearing
must send an email to <a href="/cdn-cgi/l/email-protection#d1a1a4b3bdb8b2b9b4b0a3b8bfb6a291b8a3a2ffb6bea7"><span class="__cf_email__" data-cfemail="f78782959b9e949f9296859e999084b79e8584d9909881">[email protected]</span></a> to have your legal name
added to the building access list. The subject line of the email must
contain the regulation number REG-105128-23 and the language ``TESTIFY
In Person.'' For example, the subject line may say: Request to TESTIFY
In Person at Hearing for REG-105128-23.
Individuals who want to testify by telephone at the public hearing
must send an email to <a href="/cdn-cgi/l/email-protection#ed9d988f81848e85888c9f84838a9ead849f9ec38a829b"><span class="__cf_email__" data-cfemail="1b6b6e79777278737e7a6972757c685b726968357c746d">[email protected]</span></a> to receive the telephone
number and access code for the hearing. The subject line of the email
must contain the regulation number REG-105128-23 and the language
``TESTIFY Telephonically.'' For example, the subject line may say:
Request to TESTIFY Telephonically at Hearing for REG-105128-23.
Individuals who want to attend the public hearing in person without
testifying must also send an email to <a href="/cdn-cgi/l/email-protection#027277606e6b616a6763706b6c6571426b70712c656d74"><span class="__cf_email__" data-cfemail="166663747a7f757e7377647f787165567f646538717960">[email protected]</span></a> to have
your legal name added to the building access list. The subject line of
the email must contain the regulation number REG-105128-23 and the
language ``ATTEND In Person.'' For example, the subject line may say:
Request to ATTEND In Person for REG-105128-23. Requests to attend the
public hearing must be received by 5:00 p.m. ET on November 19, 2024.
The hearing will be made accessible to people with disabilities.
Requests for special assistance during the hearing must be received by
5:00 p.m. ET on November 18, 2024.
Individuals who want to attend the public hearing by telephone
without testifying must also send an email to <a href="/cdn-cgi/l/email-protection#f9898c9b95909a919c988b90979e8ab9908b8ad79e968f"><span class="__cf_email__" data-cfemail="522227303e3b313a3733203b3c3521123b20217c353d24">[email protected]</span></a> to
receive the telephone number and access code for the hearing. The
subject line of the email must contain the regulation number REG-
105128-23 and the language ``ATTEND Hearing Telephonically.'' For
example, the subject line may say: Request to ATTEND Hearing
Telephonically for REG-105128-23. Requests to attend the public hearing
must be received by 5:00 p.m. ET on November 19, 2024.
Any questions regarding speaking at or attending the public hearing
may also be emailed to <a href="/cdn-cgi/l/email-protection#1d6d687f71747e75787c6f74737a6e5d746f6e337a726b"><span class="__cf_email__" data-cfemail="6a1a1f08060309020f0b1803040d192a031819440d051c">[email protected]</span></a>.
Oluwafunmilayo Taylor,
Section Chief, Publications and Regulations Section, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2024-26030 Filed 11-7-24; 8:45 am]
BILLING CODE 4830-01-P
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