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however, that the Preamble to the proposed regulation states that the proposed regulations
document IMAGES-009-HOUSE_OVERSIGHT_026591.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…and after the proposed regulation becomes final. Dual Consolidated Losses. The dual consolidated loss (DCL) rules are generally intended to prevent companies with tax residency in two different jurisdictions from using the same losses to obtain tax benefits in both jurisdiction...