SECTION 1. PURPOSE

This notice announces that the Department of Treasury (“Treasury Department”) and the Internal Revenue Service (“IRS”) intend to issue proposed regulations that would remove (i) the disregarded payment loss (“DPL”) rules under §1.1503(d)-1(d) and (ii) recent modifications to the dual consolidated loss (“DCL”) rules under section 1503(d) relating to the deemed ordering rule under §1.1503(d)-3(c)(3). Additionally, the proposed regulations would extend the transition relief pertaining to the application of the dual consolidated loss (“DCL”) rules under section 1503(d) to certain types of taxes covered by the so-called “GloBE Model Rules” described in “Tax Challenges Arising from the Digitalisation of the Economy

• Global Anti-Base Erosion Model Rules (Pillar Two).” ¹ Finally, this notice requests comments on certain aspects of the DCL rules.