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Finally final: The US Section 987 FX regs

Cross-border Tax Talks

CHAPTER

Navigating Code Section 987 Regulations

This chapter delves into the complexities of Code Section 987, focusing on recent final and proposed currency regulations for 2024 that significantly impact foreign branch operations and disregarded entities. The speakers discuss various methodologies for calculating gains and losses, the challenges of making initial determinations, and the implications of election choices under these new rules. Additionally, they highlight the historical context, transition rules, and critical applicability dates affecting taxpayers in the lead-up to these changes.

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