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
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
EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax