IRC Section 987: Final Regulations, IRS Notice 2026-17

Mr. Benayoun is a Principal who specializes in consulting around international taxation for inbound and outbound multinational corporations, S corporations, partnerships, and individuals and families. He has more than 10 years of business consulting experience in international taxation with Big Four firms. Mr. Benayoun's experience includes consulting around international tax reform issues from the Tax Cuts and Jobs Act as well as structuring mergers and acquisitions as well as liquidations. He has worked extensively with clients on repatriation planning; foreign-derived intangible income (FDII) planning; treaty analysis; and foreign currency issues; and U.S. CFC and anti-deferral regimes, such as Subpart F/§956/GILTI. Mr. Benayoun is well versed tax provision work (FIN 48/FAS 109), OFL/ODL analysis, debt vs. equity analysis, FTC limitation analysis and planning, tax efficient debt financing, Permanent Establishment (“PE”) risk assessment, entity rationalization planning, and inbound work including ECI, FDAP income, withholding, treaty analysis (e.g., LOB Article, PE Article, etc.), and branch profits tax issues.

Mr. Samtoy specializes in international tax consulting and compliance services. He has experience serving private equity clients, high net worth individuals, and closely held businesses across a variety of industries. Mr. Samtoy helps private equity clients with investor documentation, withholding, structuring and reporting offshore investments, and FATCA and CRS compliance. He is familiar with identifying and documenting the FATCA and CRS status of internal entities as well as filing reports with the IRS and a number of Model 1 IGA jurisdictions to report investors as required. For high-net-worth individuals and families, John assists with planning and structuring for inbound investments as well as immigration to the US. Mr. Samtoy addresses the tax considerations for individuals who are beneficiaries of foreign trusts, including the DNI and UNI calculations, as well as the required reporting on Forms 3520 and 3520-A. He assists closely held businesses with structuring their international operations and export planning, including advising on IC-DISC structures and foreign-derived intangible income (FDII). Mr. Samtoy is also experienced in various international tax compliance areas, including the various foreign asset disclosure requirements and foreign trust and estate reporting. He has presented, as a faculty member, at a number of continuing education events attended by other professionals that covered international tax compliance issues such as determining foreign tax credits, Form 5471 and Form 5472 reporting, the section 962 election for individuals, and global intangible low taxed income (GILTI).