{{item.videoDuration}}
{{item.title}}
{{item.videoDuration}}
Cross-border tax talks
Hosted by Doug McHoney, PwC's Global International Tax Services Leader, the Cross-border Tax Talks Series provides listeners with the latest trends in taxation. Various PwC specialists are featured and share insights on key issues impacting the ever-changing tax landscape.
New installments are released regularly and available for subscription at Apple Podcasts, Spotify, Overcast, and TuneIn. You can also listen at your convenience via your desktop computer or smart device.
Measure Twice, Elect Once: The Latest Section 987 Regs
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an international tax partner in PwC’s Washington National Tax Services office, who specializes in the taxation of financial transactions, including foreign currency. Doug and Laura discuss the proposed Section 987 regulations governing the new CFC election, beginning with the rule’s scope, history, and common QBU fact patterns. They explain how the election can turn off future Section 987 gain-or-loss computations, while preserving translation and basis-tracking requirements, and examine consistency across commonly controlled CFCs, partnership applications, inbound transactions, and the loss of future Section 987 losses. They also cover the 120-month amortization of pre-election amounts, the $50 million asset threshold, election timing and filing mechanics, reliance on the proposed rules, the November 12 comment deadline, and why detailed modeling is essential before making an effectively irrevocable choice.
{{filterContent.facetedTitle}}
{{contentList.loadingText}}
{{contentList.loadingText}}
Contact us
Doug McHoney
International Tax Services Global Leader, PwC US
I’m the global leader of PwC’s International Tax Services practice — and a husband, dad to canines, mentor, mentee, vlogger and podcaster.
Geoff Jacobi
ITS, Knowledge Management Managing Director, PwC US
United States
Follow us
