A Dual-Edged Sword: Exploring the Proposed DCL Regulations

In this episode, we explore the most critical aspects of the proposed dual consolidated loss, DCL, regulations, including how a DCL used in computing a Pillar Two GloBE liability could be a 'foreign use,' the effect of intercompany transactions in computing a DCL, and the potential tax liability arising from the proposed disregarded payment loss (DPL) regime targeting deduction-no inclusion outcomes. Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by returning guest, Doug Holland from the KPMG Washington National Tax International Tax group, to answer these questions and more on the latest episode of Inside International Tax.