Dual Consolidated Losses
Dual consolidated loss (DCL) rules can limit how U.S. corporate groups use losses from dual resident corporations and foreign separate units.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
1
Author(s)
AICPA staff
Availability
1 year
Product Number
USITDCL26SSO
Navigating cross-border loss limitations
DCL rules can affect how U.S. corporate taxpayers use losses from operations that are taxed in both the United States and a foreign jurisdiction. Learners will learn when DCLs arise, why the rules exist, and how they limit the ability to use the same loss against income in more than one jurisdiction.
Core rules and definitions
In this course, learners will examine the operative IRC and Treasury Regulation provisions that describe:
- The treatment of dual resident corporations
- Foreign branches
- Disregarded entities
- Hybrid entities
- Transparent entities
Learners also cover how to calculate a DCL using U.S. tax principles and how the following affect the analysis:
- Disregarded transactions
- Carryovers
- Current-year items
Domestic use and triggering events
The course covers domestic use limitations, common exceptions, and the domestic use election. It also addresses foreign use concepts, separate unit combinations, triggering events, rebuttals, and exceptions that may affect recapture.
Hands-on learning to consolidate your knowledge
Practical examples show how DCL rules apply to dual resident corporations, foreign branches, and disregarded entities. Exercises help you evaluate separate units and determine whether losses are subject to limitation.
Note: This program includes content from the U.S. International Tax Certificate.
Who Will Benefit
- Tax professionals advising U.S. corporate taxpayers with foreign operations
- International tax professionals working with consolidated groups, foreign branches, disregarded entities, or hybrid entities
- CPAs and accounting professionals who need to recognize DCL issues and escalation points
Key Topics
- Dual consolidated losses
- Dual resident corporations
- Separate units
- Foreign use
- Domestic use limitations
- Domestic use election
- Triggering events
- DCL recapture
Learning Outcomes
- Identify situations in which dual consolidated losses (DCLs) arise.
- Recognize the structural elements of DCLs.
- Identify misuse and escalation triggers.
Group ordering for your team
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