20 August 2025 IRS and Treasury announce intent to remove DPL rules and DCL deemed ordering rules The IRS and Treasury Department on August 20, 2025, in Notice 2025-44, announced the intent to issue proposed regulations that would remove the disregarded payment loss (DPL) rules under Treas. Reg. Section 1.1503(d)-1(d) and recent modifications to the dual consolidated loss (DCL) rules under IRC Section 1503(d) relating to the deemed ordering rule (see Tax Alert 2025-0288). The proposed regulations would also extend transition relief on applying the DCL rules to certain types of taxes covered by the Pillar Two GloBE Model Rules. A Tax Alert is forthcoming. Document ID: 2025-1725 |
