INCOME TAX

REG-105128-23, page 536. Section 1503(d) and the regulations thereunder determine the deductibility of certain losses of a domestic corporation. The proposed regulations provide rules that would refine certain computations and would also address the application of section 1503(d) to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax. The proposed regulations also contain rules regarding certain disregarded payments of domestic corporations that give rise to losses for foreign tax purposes.