Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed Regulations address certain considerations with respect to the operation of the DCL rules, as well as the interaction of the DCL Rules with foreign-country laws that are based on the global minimum tax model rules published by the Organisation for Economic Cooperation and Development (OECD) (GloBE Model Rules). The Proposed Regulations also include new rules to require income inclusions in connection with “disregarded payment losses”, which generally are certain payments that are disregarded for US federal income tax purposes but that give rise to losses or deductions for foreign tax purposes.