Disregarded Payment Loss Rules: How Multinationals Should Prepare

This article was originally published on June 3, 2025, in The Tax Adviser.

Treasury and the IRS on Jan. 10, 2025, released final regulations regarding dual-consolidated-loss (DCL) and disregarded payment loss (DPL) rules (T.D. 10026). These finalize proposed regulations issued on Aug. 7, 2024 (REG-105128-23). While released concurrently, the DPL rules operate separately from the DCL rules and apply to different scenarios. This article focuses on the DPL rules.

Given the regulations’ broad scope, multinational organizations should take steps to proactively assess their potential impact.

After providing some background information, this article discusses the DPL rules and illustrates them with several examples.

BDO’s Sebastian Biddlecombe, Shaiq Ibrahim, and Anke Krueger provide details in the full article in The Tax Adviser.