Andersen Managing Director Joe Calianno's comments are featured in the recent Tax Notes article, Final DPL Regs Provide Carveouts for Minority Interests. The article discusses final regulations on applying disregarded payment losses (DPLs), which generally require a domestic corporation to include a DPL in its gross income if its entity classification and payment method could give rise to a deduction/no-inclusion outcome. The final version of the regulations modifies an anti-avoidance rule to specify that it does not apply to all transactions that attempt to eliminate dual consolidated losses but only those that actively circumvent the regulations and receive unjustified benefits. Joe said this was an improvement from the proposed regulations and provided a more focused anti-avoidance rule with additional context and clarification for its application.