Cross-border Tax Talks
PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.
Cross-border Tax Talks
Lost in FX Translation: The latest 987 regs
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an International Tax Services Partner in PwC’s Washington National Tax Services practice, where she focuses on financial transactions. In this episode, recorded at PwC’s International Tax Conference in Carlsbad, Laura unpacks the latest Section 987 developments following Notice 2026-17. Doug and Laura discuss what Section 987 is, why it matters for foreign currency gain or loss in branch and disregarded entity structures, the long regulatory history from the 1991 proposed regulations through the 2024 final rules, the new simplified equity-and-basis-pool method, remittance and loss-suspension mechanics, hedging rules, the proposed CFC election, reliance and applicability dates, and practical taxpayer action items, including comment opportunities and modeling decisions for 2025 and beyond.