Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
The interaction of the U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules, which have been enacted into law by several foreign countries, may result in unintended consequences, including inconsistent and uncertain financial reporting positions. The U.S. Treasury Department must make significant changes to the DCL rules to avoid such consequences.
Read an April 2024 report* prepared by KPMG LLP professionals: Recent DCL and Pillar 2 Guidance: Comments and Recommendations
* Reproduced with permission from Tax Management International Journal, 4/2/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com