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November 27, 2023
2023-1955

Friday, December 8 | Proposed regulations under IRC Section 987: What you need to know (and do) now (1 pm ET)

Please join our panelists for an in-depth discussion of the recently released proposed IRC Section 987 regulations, which provide new guidance on determining income and currency gain or loss with respect to a qualified business unit (QBU) that uses a different functional currency than its tax owner. While the proposed regulations retain some of the framework from the 2016 and 2019 final regulations, numerous important changes have been made that will require significant analysis, data gathering and computations in advance of transitioning to the new rules.

The following topics will be discussed:

  • Important transition considerations, including a new transition rule, the difference between being on an "eligible" pre-transition method or not, and the detailed "Section 987 Transition Information" that must be provided for each IRC Section 987 QBU
  • Potential alternative approaches available under the proposed regulations, including the default foreign exchange exposure pool (FEEP) method, the Current Rate Election and the Annual Recognition Election
  • Provisions that apply prior to transition, including special rules with respect to IRC Section 987 QBU terminations
  • Characterization of IRC Section 987 gain or loss as subpart F income or global intangible low-taxed income (GILTI)

Date: Friday, December 8, 2023

Time: 1:00-2:00 p.m. ET New York; 10:00-11:00 a.m. PT Los Angeles

Registration: View archive here.

Panelists

Colleen Zeller, Partner, National Tax — International Tax and Transaction Services, Ernst & Young LLP

Tim Kerr, Partner, National Tax — International Tax and Transaction Services, Ernst & Young LLP

Ray Stahl, Principal, National Tax — International Tax and Transaction Services, Ernst & Young LLP

Moderator

Lee Holt, Partner, National Tax — International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: up to 1.2 depending on duration. Recommended field of study: Taxes. Learning objectives: Analyze how the proposed Section 987 regulations differ from 2016 and 2019 final regulations; identify important transition considerations; recognize alternative elections available under the proposed regulations. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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