News & Analysis as of May 4, 2025

GILTI tax

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Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on 3/11/2025

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

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Internal Revenue Code (IRC) › Regulatory Requirements › GILTI tax

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

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