• videocam Live Webinar with Live Q&A
  • calendar_month October 27, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

U.S. Foreign Currency Reporting Requirements: New Sec. 987 Rules, IRS Notice 2026-17, Exemptions, Tax Planning

Early Bird Pricing!
MSRP
$347.00
$294.95
Save $52.05

Discount expires 10/13/26

This course is $0 with these passes:

CLE
CPE
ALL
  1. keyboard_arrow_leftBack

About the Course

Introduction

This CLE/CPE webinar will provide attorneys and tax professionals guidance on IRC Section 987: The 2004 final regulations, and more recent IRS guidance for taxpayers. The panel will discuss the application of Section 987 to foreign branches and controlled foreign corporations (CFCs), options, and tax planning considerations.

Description

The IRS final regulations for foreign currency reporting include provisions that significantly impact companies with foreign operations. Section 987 introduces updated foreign currency reporting requirements effective for the 2025 tax year onward. Tax counsel must have a complete understanding of these rules and recent IRS guidance to assist taxpayers in avoiding penalties and maintaining compliance.

Section 987 covers how taxpayers with qualified business units (QBUs) operating overseas calculate taxable income and foreign currency gains or losses. Taxpayers have struggled with the application of Sec. 987 and methods of calculating income stemming from overseas operations, prompting the release of IRS Notice 2026-17, which provides guidance to ease the complexity of these rules.

IRS Notice 2026-17 includes an option to elect to use an earnings and basis pool method for calculating Section 987 gains and losses and an exemption election for CFCs. Tax counsel and businesses with foreign operations must evaluate elections and exemptions under the new rules, and understand the impact of Sec. 987 on international tax planning.

Listen as our panel discusses Section 987 reporting requirements, recent developments, the pros and cons of new elections and exemptions, and offers tax planning guidance for taxpayers with foreign business operations.

Presented By

Doug Chestnut, CPA
Managing Director
BDO USA

Mr. Chestnut is a Managing Director in BDO’s Washington National Tax office and serves as the Capital Markets Practice Leader. He works with BDO's U.S. offices in helping clients maximize the use of financial products and overall treasury management from a tax perspective. Mr. Chestnut has more than 30 years of experience in international tax and financial products. He has experience in many areas of capital markets transaction taxation including foreign currency transactions from both U.S. and subpart F perspectives, DASTM, foreign currency hedging, interest rate hedging, cash pooling, and treasury centers. Mr. Chestnut also has experience assisting clients in the area of commodity trading, dealing and hedging.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Mike Harper
Director
KBF Advisory, LLC

Mr. Harper is a Director at KBF Advisory with more than 30 years of experience advising clients on international tax planning and cross-border transactions. He specializes in helping multinational businesses, investment funds, and real estate investors navigate complex global tax issues while developing tax-efficient transaction structures. Mr. Harper's practice focuses on inbound and outbound investment planning, international mergers and acquisitions, treaty planning, cross-border real estate transactions, foreign currency matters, Subpart F, GILTI, PFIC, and other U.S. international tax rules. He works with a diverse client base that includes technology companies, hedge funds, REITs, strategic investors, and high-net-worth individuals.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, October 27, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. What Section 987 is and who must transition to the final regulations

II. The 2024 Final Regulations: FEEP, CR and AR

III. IRS Notice 2026-17 and the EBPM

IV. Elections & Examples

V. Hedging

VI. Transition

VII. The CFC Exemption Election

VIII. Critical Data for Assessment

IX. Forms

The panel will review these and other key issues:

  • Impact of 2024 final regulations
  • Application and mechanics of IRC Section 987 for foreign business operations, branches, and other QBUs
  • New equity and basis pool election and related simplification provisions
  • Comparing calculation methods under the final regulations and proposed alternatives under IRS Notice 2026-17
  • Assessment of options and elections and how they impact hedging

Learning Objectives

After completing this course, you will be able to:

  • Identify the principal requirements of IRC Section 987 and related regulations
  • Ascertain available Section 987 computational methods and elections
  • Evaluate planning and compliance considerations arising from recent IRS guidance
  • Decide the impact of IRS Notice 2026-17 on 2024 prior regulations
  • Determine how Section 987 applies to foreign branches, DREs, and other QBUs


  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation, including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .