INCOME TAX

REG-107895-24, page 972. These proposed regulations provide guidance regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.

Finding Lists begin on page ii.

T.D. 10026, page 878. This document contains final regulations regarding certain disregarded payments that give rise to deductions for foreign tax purposes and potential double non-taxation of income. The final regulations affect domestic corporate owners that make or receive such payments. This document also announces additional transition relief for the application of the dual consolidated loss (“DCL”) rules to certain foreign taxes that are intended to ensure that multinational enterprises pay a minimum level of tax.

T.D. 10029, page 936. This document contains final regulations that identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions, a type of reportable transaction, and certain other micro-captive transactions as transactions of interest, another type of reportable transaction.