Treasury’s proposed Section 987 regulations introduce an elective equity and basis pool method that shifts away from the complex 2024 framework. Companies now face a new set of decisions around elections, modeling, and financial reporting as they evaluate whether the proposal offers real simplification or simply a different kind of complexity.

IN THIS EPISODE
Isabel Barbosa, Managing Director, PwC’s International Tax Services Practice
Laura Valestin, Partner, PwC’s International Tax Services Practice

IN CASE YOU MISSED IT
Watch episodes filmed at this year’s International Tax Conference (March 2026)

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