Cross-border Tax Talks
Finally final: The US Section 987 FX regs
Feb 6, 2025
Rebecca Lee, an International Tax Principal at PwC specializing in financial transactions and digital assets, joins Doug McHoney for a deep dive into the final and proposed regulations under Section 987. They explore methods for calculating foreign currency gains and losses for qualified business units, major changes in regulations, and implications for partnerships. The conversation also highlights the historic context and discusses the significance of compliance amidst upcoming 2024 changes, stressing the need for taxpayers to stay informed and proactive.
40:16
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Quick takeaways
- The final regulations under Section 987 introduce a structured framework for calculating foreign currency gains and losses using the Foreign Exchange Exposure Pool method.
- Controversial suspended loss rules are now in place to limit loss recognition, ensuring taxpayer compliance and protecting tax revenue integrity in currency transactions.
Deep dives
PwC's Pillar 2 Engine Revolutionizes Compliance
PwC's Pillar 2 engine is a centralized cloud-based tool designed to streamline compliance calculations for international tax regulations. It utilizes a sophisticated graph system built over 20 years of tax technology experience, aligning various compliance activities such as modeling and provision calculations effectively. Developed by a global team of experts, this engine marks a significant advancement in managing the complexities of Pillar 2 requirements. It is now offered as a licensed service, providing companies access to enhanced compliance solutions.
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