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Foreign Currency Transactions: Tax Compliance Amidst Continued Uncertainty

Deloitte Dbriefs | International Tax

Start date and time

October 31, 2013 2:00 PM

End date and time

October 31, 2013 3:00 PM

Time zone:

(GMT-05:00) Eastern Time (US & Canada)

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Host: Gretchen Sierra, Principal - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes 

With continued volatility in foreign exchange markets and increased IRS scrutiny of related financial products and transactions, tax treatment of many common types of currency transactions remains uncertain. How can you address this uncertainty? We'll discuss:

  • Potential issues with subpart F treatment of hedges of disregarded transactions and interest-bearing liabilities entered into by foreign treasury centers and other controlled foreign corporations.
  • Planning for the impending finalization of regulations under section 987.
  • Recent regulations addressing the integration of nonfunctional currency-denominated debt and related hedging transactions under section 988(d).

Gain fresh insights on this challenging area of tax compliance and learn ways to address related uncertainty.

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