### Question
How does Returns and Payment of Tax define dual consolidated loss?


### Answer
Under *26 U.S.C. § 1503*, **dual consolidated loss** is defined as:

> any net operating loss of a domestic corporation which is subject to an income tax of a foreign country on its income without regard to whether such income is from sources in or outside of such foreign country, or is subject to such a tax on a residence basis

#### Citation:
  - *26 U.S.C. § 1503*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 6-CONSOLIDATED RETURNS > Subchapter A-Returns and Payment of Tax**

