On October 20, 2025, TEI submitted comments on Notice 2025-44, which announced the forthcoming withdrawal of final regulations regarding disregarded payments losses and related changes to the dual consolidated loss (DCL) rules, among other things. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments. The letter included comments on the definition of foreign use, the DCL rules’ treatment of disregarded payments, the interaction of the DCL regime and Top-Up Taxes, and income arising from stock of foreign corporations.
Read the comments here
Committee