AICPA Comments on Notice 2025-44, All or Nothing Approach to Dual Consolidated

The AICPA sent a letter to both the IRS and Treasury in response to Notice 2025-44 commenting on the “all or nothing” rule to dual consolidated losses. The letter recommends Treasury and the IRS issue guidance stating that if the “all or nothing” approach is retained, the items of deduction or loss (or portions thereof) that represent a permanent difference between U.S. federal income tax law and foreign law are excluded from the computation of a dual consolidated loss (DCL).