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Apr 20

Branch Transactions – New Aggregation Election

Do you have a business that has a branch in a foreign country?  If so, new regulations will dictate how you determine your taxable income. Many businesses have a branch in a foreign country.  This may include conducting business in the foreign country through an… Read More

Jan 10

Final Section 987 Regulations for “Qualified Business Units”

In December of 2016, the Treasury issued final and temporary functional currency regulations that apply to certain types of so-called “qualified business units”. A qualified business unit or “QBU” includes a corporation.  In addition, activities of a corporation or an individual qualify as a QBU… Read More