Section 987 is Coming Back from the Dead

GTM’s Raymond Wynman and Ross McKinney will walk you through the complexities and opportunities of the 2023 Proposed Section 987 Regulations. The new regulations are expected to be finalized in Q4 of 2024 and become effective for tax years starting in 2025. The rules introduce significant changes to how foreign exchange gains and losses are calculated for foreign disregarded entities and branches. Don’t miss this chance to stay ahead of the curve, as our team breaks down the upcoming regulatory shifts and provide strategies to help your organization navigate them smoothly and effectively.

Key Learnings:

• Understand the Core Changes: Gain a clear understanding of the changes introduced by the 2023 Proposed Regulations versus the previous iterations dating back to 1991.
• Options for Adoption:  Make informed decisions with respect to early-adoption (2023/2024), the impact of your current 987 methodology (if any), and unrecognized pre-transition gain/loss calculations.
• New Elections and Their Impacts: Explore the new group-level elections introduced by the regulations and analyze how they can be optimized to benefit your tax profile.
• Phased Impact Assessment: Assess your current methodology and risk profile, compute your pre-transition gain/loss, and determine on-going data needs to adopt the new methodology and its various elections while weighing both cash tax and ETR implications.

This webinar is an essential opportunity to stay ahead of regulatory changes and ensure your organization is well-prepared for the coming tax year.