Taxpayers have faced uncertainty as to how to properly account for their foreign branch operations since Congress first enacted section 987 due to the lack of currently applicable Treasury Regulations.
On November 14, 2023, IRS and Treasury published proposed regulations under section 987. Largely consistent with the regulations proposed in 2006 and 2016, these regulations require taxpayers to employ a complex methodology, especially in comparison with the profit-and-loss methodologies commonly employed by taxpayers today.
This one-hour TaxWatch webcast featuring professionals from our International Tax practice, focuses on the following areas:
- Overview of the new proposed section 987 regulations
- Significant changes from prior regulations
- The new transition rules
- Various elections available to taxpayers and related loss limitations
- Looking ahead to expected applicability date