Recently released final and proposed regulations under Section 987 providing guidance for determining income and currency gain or loss for certain qualified business units (QBUs) would generally apply for tax years beginning after December 31, 2024. These regulations will generally require companies to engage in significant analysis, data gathering, and detailed transitional computations.

Please join EY thought leaders for an in-depth discussion of these regulations, including:

• Complex transition considerations, including determining pretransition gain or loss and required transition reporting requirements
• Available computational alternatives, including the default method, the current rate election and the annual recognition election
• Pre-transition tax year considerations
• When and how suspended losses are recognized
• Characterizing Section 987 gain or loss of a controlled foreign corporation

Date: Friday, January 10, 2025

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

Registration: Register for this event.

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 objective: Identify key elements of the Section 987 regulations, analyze transition considerations and assess various alternatives that are available, as well as rules on the computation of unrecognized gain or loss and recognition of suspended losses. 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.

EY webcast managed and produced by Ernst & Young LLP's Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Barbara Kirchheimer | barbara.kirchheimer@ey.com

Learn about and register for EY Tax webcasts

You can learn about and register for any EY Tax webcast here.