KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules
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
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.