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Final Currency Rules for Foreign Branches – Section 987 Regulations

February 4, 2025 @ 2:00 pm – 3:00 pm EST
Event description
Over the course of almost 4 decades, Congress and the IRS have enacted various laws, regulations, and guidance to ensure that taxpayers engaging in certain foreign currency transactions do so in a manner that is consistent and reasonable. These rules span from taxpayers operating in hyperinflationary global markets to taxpayers that transact in multiple currencies.
More recently, the IRS has issued guidance on the branch transaction rules that are covered under Section 987. These rules generally apply to taxpayers that have one or more qualified business units (QBUs) with a functional currency that is different from that of the QBU’s tax owner.
In this webcast, we will unpack the final regulations by providing an overview of the scope and applicability, by discussing the transition rules, and by covering several new simplifying elections that are available to taxpayers.
Date and time
Tuesday, February 04, 2025
2:00 PM ET – 3:00 PM ET
Recommended CPE credits
1
Learning objectives
Determine how these developments would apply under certain facts and circumstance and assess the impact.
Demonstrate a working knowledge of recent international tax developments.
Analyze developments and guidance to determine their effects on your organization.





