[Federal Register Volume 89, Number 217 (Friday, November 8, 2024)]
[Proposed Rules]
[Page 88686]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-26030]



[[Page 88686]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[REG-105128-23]
RIN 1545-BQ72


Rules Regarding Dual Consolidated Losses and the Treatment of 
Certain Disregarded Payments; Hearing

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; public hearing.

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SUMMARY: This document provides a notice of public hearing on the 
proposed rule (REG-105128-23) that was published in the Federal 
Register on Wednesday, August 7, 2024. The proposed regulations relate 
to certain issues arising under the dual consolidated loss rules, 
including the effect of intercompany transactions and items arising 
from stock ownership in calculating a dual consolidated loss. The 
proposed regulations also address the application of the dual 
consolidated loss rules to certain foreign taxes that are intended to 
ensure that multinational enterprises pay a minimum level of tax, 
including exceptions to the application of the dual consolidated loss 
rules with respect to such foreign taxes. Finally, the proposed 
regulations include rules regarding certain disregarded payments that 
give rise to losses for foreign tax purposes.

DATES: The public hearing is scheduled to be held on November 22, 2024, 
at 10:00 a.m. Eastern Time (ET). The IRS must receive speakers' 
outlines of topics to be discussed at the public hearing by November 
14, 2024. If no outlines are received by November 14, 2024, the public 
hearing will be cancelled.

ADDRESSES: The public hearing is being held in the Auditorium, at the 
Internal Revenue Service Building, 1111 Constitution Avenue NW, 
Washington, DC. Due to security procedures, visitors must enter at the 
Constitution Avenue entrance. In addition, all visitors must present a 
valid photo identification to enter the building. Because of access 
restrictions, visitors will not be admitted beyond the immediate 
entrance area more than 30 minutes before the hearing starts. 
Participants may alternatively testify or attend the hearing by 
telephone.
    Send an outline of topic submissions electronically via the Federal 
eRulemaking Portal at www.regulations.gov (indicate IRS and REG-105128-
23). Send paper submissions to CC:PA:01:PR (REG-105128-23), Room 5205, 
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, 
Washington, DC 20044.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Andrew L. Wigmore at (202) 317-5443; concerning the submission of 
requests to testify, the hearing, the access code to attend the hearing 
by phone, or to be placed on the building access list to attend the 
public hearing, contact the Publications and Regulations Section at 
(202) 317-6901 (not a toll-free number), or by email at 
<a href="/cdn-cgi/l/email-protection#75050017191c161d1014071c1b1206351c07065b121a03"><span class="__cf_email__" data-cfemail="d9a9acbbb5b0bab1bcb8abb0b7beaa99b0abaaf7beb6af">[email protected]</span></a> (preferred).

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the 
notice of proposed rulemaking (REG-105128-23) that was published in the 
Federal Register on Wednesday, August 7, 2024 (89 FR 64750).
    The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who 
wish to present oral comments at the hearing must submit an outline of 
the topics to be discussed and the time to be devoted to each topic by 
November 14, 2024.
    A period of 10 minutes will be allotted to each person for making 
comments. An agenda showing the scheduling of the speakers will be 
prepared after the deadline for receiving outlines has passed. Copies 
of the agenda will be available free of charge at the hearing and via 
the Federal eRulemaking Portal (https://www.Regulations.gov) under the 
title of Supporting & Related Material. If no outline of the topics to 
be discussed at the hearing is received by November 14, 2024, the 
public hearing will be cancelled. If the public hearing is cancelled, a 
notice of cancellation of the public hearing will be published in the 
Federal Register.
    Individuals who want to testify in person at the public hearing 
must send an email to <a href="/cdn-cgi/l/email-protection#d1a1a4b3bdb8b2b9b4b0a3b8bfb6a291b8a3a2ffb6bea7"><span class="__cf_email__" data-cfemail="f78782959b9e949f9296859e999084b79e8584d9909881">[email protected]</span></a> to have your legal name 
added to the building access list. The subject line of the email must 
contain the regulation number REG-105128-23 and the language ``TESTIFY 
In Person.'' For example, the subject line may say: Request to TESTIFY 
In Person at Hearing for REG-105128-23.
    Individuals who want to testify by telephone at the public hearing 
must send an email to <a href="/cdn-cgi/l/email-protection#ed9d988f81848e85888c9f84838a9ead849f9ec38a829b"><span class="__cf_email__" data-cfemail="1b6b6e79777278737e7a6972757c685b726968357c746d">[email protected]</span></a> to receive the telephone 
number and access code for the hearing. The subject line of the email 
must contain the regulation number REG-105128-23 and the language 
``TESTIFY Telephonically.'' For example, the subject line may say: 
Request to TESTIFY Telephonically at Hearing for REG-105128-23.
    Individuals who want to attend the public hearing in person without 
testifying must also send an email to <a href="/cdn-cgi/l/email-protection#027277606e6b616a6763706b6c6571426b70712c656d74"><span class="__cf_email__" data-cfemail="166663747a7f757e7377647f787165567f646538717960">[email protected]</span></a> to have 
your legal name added to the building access list. The subject line of 
the email must contain the regulation number REG-105128-23 and the 
language ``ATTEND In Person.'' For example, the subject line may say: 
Request to ATTEND In Person for REG-105128-23. Requests to attend the 
public hearing must be received by 5:00 p.m. ET on November 19, 2024. 
The hearing will be made accessible to people with disabilities. 
Requests for special assistance during the hearing must be received by 
5:00 p.m. ET on November 18, 2024.
    Individuals who want to attend the public hearing by telephone 
without testifying must also send an email to <a href="/cdn-cgi/l/email-protection#f9898c9b95909a919c988b90979e8ab9908b8ad79e968f"><span class="__cf_email__" data-cfemail="522227303e3b313a3733203b3c3521123b20217c353d24">[email protected]</span></a> to 
receive the telephone number and access code for the hearing. The 
subject line of the email must contain the regulation number REG-
105128-23 and the language ``ATTEND Hearing Telephonically.'' For 
example, the subject line may say: Request to ATTEND Hearing 
Telephonically for REG-105128-23. Requests to attend the public hearing 
must be received by 5:00 p.m. ET on November 19, 2024.
    Any questions regarding speaking at or attending the public hearing 
may also be emailed to <a href="/cdn-cgi/l/email-protection#1d6d687f71747e75787c6f74737a6e5d746f6e337a726b"><span class="__cf_email__" data-cfemail="6a1a1f08060309020f0b1803040d192a031819440d051c">[email protected]</span></a>.

Oluwafunmilayo Taylor,
Section Chief, Publications and Regulations Section, Associate Chief 
Counsel (Procedure and Administration).
[FR Doc. 2024-26030 Filed 11-7-24; 8:45 am]
BILLING CODE 4830-01-P


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