Taxing FX of Branches: the new Section 987 regulations
Cross-border Tax Talks
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Complexity of the recent tax regulations on foreign currency translation
Recent tax regulations on the taxation of foreign currency translation aim to reflect economic reality and prevent taxpayers from manipulating losses. The proposed regulations largely retain the methodology of the 2016 final regulations but are not yet effective. The new regulations are dense and complex, with over 250 pages of challenging content, making it one of the most difficult things to navigate and digest. Even experts are still in the early stages of learning and understanding these regulations.
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