News & Analysis as of September 6, 2025

Comment Period

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IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

Eversheds Sutherland (US) LLP on 9/3/2025

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

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IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

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