www.aoshearman.com/en/insights/proposed-dual-consolidated-loss-regulations-would-disallow-us-tax-use-of-foreign-losses
insightplus.bakermckenzie.com/bm/tax/united-states-proposed-dpl-rules-create-immediate-risks-for-many-ctb-elections
rsmus.com/insights/tax-alerts/irs-releases-proposed-dual-consolidated-loss-regulations.html
Update:
Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two
G7 Agreement on Pillar 2 measures, US retaliatory taxes dropped | A&L Goodbody LLP