Section 987 services
IT.QCS §987 services
New IRS regulations require U.S.-based multinational companies to adopt a "reasonable method" for calculating §987 gains and losses from currency fluctuations. This can be a complex challenge because the new regulations give taxpayers several options for compliance.
To decide on the most beneficial method, you need accurate data and the ability to model the various scenarios. Also, you need to consider the FIN 48 (Financial Accounting Standards Board Interpretation 48) implications of your choice, because the method must support a "more-likely-than-not" §987 position to meet the required FIN 48 recognition threshold.
Deloitte Tax LLP's International Tax Quantitative Consulting Services (IT.QCS) can help. Our §987 services provide tax-technical specialization, order, efficiency and speed to your §987 attribute studies. With our tax technical resources and tools, IT.QCS can help you address compliance with potential FIN 48 implications of §987 and produce a more accurate tax provision. We can also help you explore beneficial §987 positions on Form 8858, gain access to ready and reliable information for planning purposes, and improve the efficiency and accuracy of your company's interest allocation calculation.
Learn more about how IT.QCS can deliver the integrated, flexible and sustainable services you need to address your company's exposure in today's complex international tax environment.