The American Institute of CPAs (AICPA) sent comments to the Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) regarding dual consolidated losses (DCL) and the treatment of certain disregarded payments. These comments are in addition to our letter previously submitted to the Treasury and the IRS on February 8, 2024, requesting guidance on the interaction between the DCL rules and the jurisdictional blending rules under Pillar Two.
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Dual Consolidated Losses Comment Letter
Oct 02, 2024 · 322.8 KB Download
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File name: Dual Consolidated Losses Comment Letter
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