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Disregarded Payment Loss (DPL) and Dual Consolidated Loss (DCL) – Interim Guidance IRS Notice 2025-44
IRS Eases DPL and DCL Compliance Burdens: What Notice 2025-44 Means for U.S. Multinationals.

Indhira Demorizi
Aug 232 min read
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Section 951B – A U.S. Anti-Deferral Regime - 5 Things You Should Know
U.S. Companies and Private Funds - Heads Up!
If your structure involves foreign affiliates or complex ownership layers, the new Section 951B may impact you.

Indhira Demorizi
Jul 255 min read
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