Cross-border tax talks

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July 09, 2019

Branch FX: Were those Section 987 regulations final?

Doug and Laura cover the basic mechanics and complications of foreign currency transactions as well as the history of the regulations. They also discuss how taxpayers are applying the regulations and how Section 987 interacts with the global intangible low-taxed income (GILTI) regime and subpart F. The discussion concludes with information about qualified business units (QBUs) and Doug and Laura's perspectives on whether we might see more proposed regulations.

Duration: 35:23

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Doug McHoney

International Tax Services Co-Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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