Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
3/11/2025
/ Compliance ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Regulatory Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming.
Under the...more
On August 7, 2022, the US Senate passed the Inflation Reduction Act of 2022 (the Act), a budget reconciliation bill recently introduced by Senate Majority Leader Chuck Schumer (D-NY) and Senator Joe Manchin (D-WV). The bill...more
The Inflation Reduction Act of 2022 includes an excise tax that, if enacted, will make share repurchases by publicly traded companies more costly starting in 2023. The proposed tax is meant to be a significant revenue-raiser,...more