The US Internal Revenue Service (IRS) and Treasury announced a public hearing regarding the proposed Rules on Dual Consolidated Losses and Certain Disregarded Payments on 11 November 2024.

This document provides a notice of public hearing on the proposed rule (REG-105128-23) that was published in the Federal Register on Wednesday, 7 August 2024. The proposed regulations relate to certain issues arising under the dual consolidated loss rules, including the effect of intercompany transactions and items arising from stock ownership in calculating a dual consolidated loss.

The proposed regulations also address the application of the dual consolidated loss rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax, including exceptions to the application of the dual consolidated loss rules with respect to such foreign taxes. Finally, the proposed regulations include rules regarding certain disregarded payments that give rise to losses for foreign tax purposes.

Dates

The public hearing is scheduled to be held on 22 November 2024, at 10:00 AM Eastern Time (ET). The IRS must receive speakers’ outlines of topics to be discussed at the public hearing by 14 November 2024. If no outlines are received by 14 November 2024, the public hearing will be cancelled.

Addresses

The public hearing is being held in the Auditorium, at the Internal Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC. Due to security procedures, visitors must enter at the Constitution Avenue entrance. In addition, all visitors must present a valid photo identification to enter the building. Because of access restrictions, visitors will not be admitted beyond the immediate entrance area more than 30 minutes before the hearing starts. Participants may alternatively testify or attend the hearing by telephone.

Send an outline of topic submissions electronically via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG-105128-23).

Send paper submissions to CC:PA:01:PR (REG-105128-23), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.