Sullivan
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Lewis Greenwald was quoted in the article “Timing Wrinkle Could Muddle Foreign Currency Tax Rules” published by Law360 Tax Authority [sub. req’d.] on May 18, 2026. The article discusses proposed U.S. Treasury guidance related to Internal Revenue Code Section 987 and concerns from tax practitioners and multinational companies regarding the timing of additional guidance ahead of the October 15 filing deadline for 2025 returns.

Lewis discussed the complexity of the regulations introduced in 2006 and the tax community’s longstanding preference for the earlier framework proposed in 1991, noting, “Since ’06, everybody and their mother has been clamoring to bring back the ’91 method, because it was a method that’s fairly easy to comply with.”