October 22, 2024

IRS Consolidated Loss Rules Would Jack Up U.S. Corporate Tax Rate

Bloomberg Law
Tax attorney Joshua Odintz was quoted in a Bloomberg Law article about proposed changes to the dual consolidated loss regulations by the U.S. Department of the Treasury. The article discussed how these changes could significantly increase the effective tax rates for multinational companies. Mr. Odintz and other tax professionals interviewed argued that the proposed regulations depart from the original intent of the law and attempt to implement Organization for Economic Cooperation and Development (OECD) standards that Congress did not adopt. They suggested that the Treasury Department may be overstepping its authority by making such sweeping changes to the tax code without congressional approval.

"Not only did the United States, once again, not adopt it, but when it had a chance to do so, Congress purposely did not go down that path," he said. "It's a very strained reading of Section 1503."

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