Notice 2025-44: Treasury and the IRS intend to issue proposed regulations withdrawing the disregarded payment loss (“DPL”) rules

Notice 2025-44 announces that Treasury and the IRS intend to issue proposed regulations withdrawing the disregarded payment loss (“DPL”) rules under § 1.1503(d)-1(d). The DPL rules were finalized on January 14, 2025 and are applicable with respect to losses incurred in taxable years beginning on or after January 1, 2026. In addition, this notice announces an extension of the transition relief initially announced in Notice 2023-80 with respect to the interaction of the dual consolidated loss (“DCL”) rules and the model rules published by the OECD/G20 Inclusive Framework on BEPS (the “GloBE Model Rules”). The notice extends the transition relief such that the DCL rules would generally be applied without respect to the GloBE Model Rules for losses incurred in taxable years beginning before January 1, 2028.

Notice 2025-44 will be in IRB:2025-37, dated: September 08, 2025

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