Dual Consolidated Losses: New Proposed Regulations
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the fundamentals of the dual consolidated loss (DCL) rules under IRC Section 1503(d) to global entity structures and the effect of the new proposed regulations on existing structures for international companies and their advisers. Our panel of international mergers and acquisitions strategists will present examples and scenarios applying the existing and proposed guidelines.
Outline
- Dual consolidated losses: introduction
- Overview
- Key definitions
- Calculation of DCLs
- Foreign use
- Domestic use limitation
- Domestic use election and triggering events and exceptions
- Proposed regulations
- Disregarded payment rules
- Income with respect to stock
- Books and records “clarification”
- Pillar II
- Intercompany transactions
Benefits
The panel will cover these and other critical issues:
- Entities subject to IRC Section 1503(d) DCL rules
- Proposed regulations REG-105128-23 and their impact
Faculty
Neil Feinstein
Managing Director, National Tax Office, International Tax Service
BDO USA
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on... | Read More
Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on domestic and international mergers and acquisitions and other business transactions, structuring of international operations (including tax efficient supply chains), financial products, and foreign currency transactions, as well as on other tax matters. His clients have included companies in the manufacturing, pharmaceuticals, specialty chemicals, and financial services industries, among other industries. Mr. Feinstein joined BDO in November 2022 after retiring as a managing director from Deloitte Tax LLP in 2020. Prior to joining Deloitte in 1996, he was partner in the law firm of Duane, Morris & Heckscher and in the law firm of Zapruder & Odell. Mr. Feinstein began his career as a tax associate at the law firm of Morgan, Lewis & Bockius.
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Michael Masciangelo, CPA
Tax Partner; International Tax Services Practice Leader
BDO USA
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S.... | Read More
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.
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