About the Course
Introduction
This webinar will provide tax professionals with a comprehensive analysis of IRC Section 987, including the 2024 final regulations and recent IRS guidance introducing significant simplification opportunities for taxpayers with qualified business units (QBUs). Our panel of knowledgeable international tax professionals will discuss the practical application of Section 987 to foreign branches, disregarded entities, and controlled foreign corporations, highlighting key compliance requirements, computational challenges, and planning considerations facing multinational taxpayers. The program will focus on both the mechanics of Section 987 and the practical decisions taxpayers must make when evaluating newly available alternatives.
Description
The IRS and Treasury continue to refine the Section 987 regime in response to longstanding practitioner concerns over its complexity. IRS Notice 2026-17 announced the Treasury Department's intention to issue proposed regulations under Section 987. It introduces an elective approach modeled on the historic equity and basis pool methodology for calculating a QBU's gain or loss, expands eligible Section 987 hedging transactions, and provides a framework for a controlled foreign corporation exemption election. These developments require multinational businesses and their advisers to revisit existing modeling assumptions, evaluate whether available elections may produce more favorable results, and consider the interaction of Section 987 with broader international tax planning objectives.
Listen as our accomplished panel explains the latest Section 987 developments, analyzes the advantages and limitations of newly available elections and computational methods, and provides practical guidance for determining when these alternatives may simplify compliance, improve tax results, or create additional planning opportunities.
Presented By
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).
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
-
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Thursday, December 3, 2026
- schedule
1:00 PM ET/10:00 AM PT
1. What Is Section 987?
2. The Rules Before the Final Regulations
3. The 2024 Final Regulations
4. Calculating Pre-Transition Gain or Loss
5. Acceptable Methods
6. Available Elections
7. Required Forms & Reporting
8. Notice 2026-17
9. August 2026 Proposed Regulations – Exempt CFCs
10. Planning Opportunities
The panel will review these and other key issues:
- Understanding the purpose and mechanics of IRC Section 987
- Applying Section 987 to foreign branches, disregarded entities, and other QBUs
- Analyzing the 2024 final regulations and their practical impact
- Evaluating the new equity and basis pool election and related simplification provisions
- Comparing computational methods under the final regulations and proposed alternatives
- Determining whether available elections produce favorable tax and operational outcomes
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.
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 .
Recommended Resources
