Notice 2025-44, page 386.

This notice announces a forthcoming withdrawal of the disregarded payment loss (“DPL”) rules under § 1.1503(d)-1(d). The DPL rules were finalized on January 14, 2025 and would have been applicable with respect to losses incurred in taxable years beginning on or after January 1, 2026. In addition, this notice announces an additional extension of the transition relief initially announced in Notice 2023-80 with respect

Finding Lists begin on page ii.

to the interaction of the dual consolidated loss rules and the model rules published by the OECD/G20 Inclusive Framework on BEPS.