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

Mr. Benayoun has over 15+ years of business consulting experience with national and Big Four firms. He specializes in international taxation of inbound and outbound multi-national and non-resident alien (NRA) clients.

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).