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NORTH AMERICA: "Autos: North America Production Seen Inflecting Higher in Q3 2015" report

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back to index backAMERItalk April,  2007


New tax provisions expand availability of cross-border losses to substantially reduce global tax liabilities

The IRS recently released final rules, T.D. 9315, on dual consolidated losses (DCL) that dropped significant restrictions on loss use and substantially increased the tax savings opportunities in multiple jurisdictions for cross-border organizations.

The new rules, which were several years in the making, address DCLs, which are designed to stop companies with tax residency in two jurisdictions from using the same loss to get benefits in both countries. Nonetheless, the new rules, but substantially limiting the areas where the losses are disallowed, increase the opportunities to utilize the same losses in more than one jurisdiction where tax avoidance is not a primary purpose of the taxpayer's activities.

Among the more favorable changes, the IRS cut the period for certification that there are no double-dipping losses from seven years to five years, expanded a rule on combining separate units to utilize losses, and retroactively dropped controversial basis adjustment rules.

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Source: Butzel Long - GAI


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