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Taxing FX of Branches: the new Section 987 regulations

Cross-border Tax Talks

CHAPTER

Downstream Consequences and Comment Period for Proposed Regulations

This chapter discusses the potential effects of the proposed regulations on historical exposure, including impacts on deferred tax assets, deferred tax liabilities, corporate alternative minimum tax, and pillar two global minimum tax calculations. The chapter also highlights the comment period for taxpayers to share their input and suggestions.

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