The U.S. IRS and Treasury have issued final Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, which were published in the Federal Register on 14 January 2025. This includes rules for disregarded payment losses (DPL) and a DPL anti-avoidance rule that apply to tax years of owners of disregarded payment entities (DPEs) beginning on or after 1 January 202…