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IFA USA Westchester-Connecticut Regional Event
When: April 30, 2026
Location: Stamford, CT
People: Lewis J. Greenwald and Eric J. Rietveld

Lewis Greenwald and Eric Rietveld presented "IRS Notice 2026-17 Modifications to Rules for Computing Taxable Income or Loss and Foreign Currency Gain or Loss Under Section 987" at the IFA USA Westchester-Connecticut Regional Event in Stamford, Connecticut, on April 30, 2026.

Over the past 35 years, there have been a series of regulations regarding computing taxable income or loss and foreign currency gain or loss under section 987. IRS Notice 2026-17 announced that Treasury and the IRS will be issuing proposed regulations that will bring us back to the far simpler method described in the 1991 proposed regulations with certain modifications. With that background in mind, Lew and Eric's presentation focused on the following learning objectives: 

  • Understanding the original 1991 proposed section 987 regulations methodology;
  • Learning about the subsequent section 987 regulations; and
  • Understanding the proposed modification to the 1991 proposed regulations methodology.