Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, Disregarded Payment Loss Rules Are Dead; Is All-or-Nothing Next? The article focuses on the so-called all-or-nothing principle that is part of the dual consolidated loss (DCL) rules. In August 2025, IRS and Treasury issued Notice 2025-244, which, among other things, asked commentators to address whether the all-or-nothing principle, which requires the recapture of the entire DCLs if any portion of them is made available for foreign use, should be revised. The notice highlighted administrability concerns to adopting an alternative approach. Joe told Tax Notes that the all-or-nothing rule is an antiquated, unduly harsh rule that should be eliminated. Limiting the application of the DCL rules to amounts actually put to foreign use, instead of imposing a blanket all-or-nothing approach, would not add to the administrative complexity because taxpayers are already doing this analysis, Joe said.