Navigating the New Section 987 Regulations: Foreign Currency Gain and Loss for Foreign Branches and Branch-like Entities
The U.S. Treasury Department and the IRS released proposed regulations under Internal Revenue Code (IRC) section 987. The proposed rules provide long-sought guidance for taxpayers on how to calculate foreign exchange gains and losses of foreign branches and certain non-U.S. entities treated as disregarded entities for U.S. federal income tax purposes, which are referr [...]
