On March 11, 2025, TEI filed comments with the IRS and U.S. Department of the Treasury regarding proposed regulations under section 987, which were published on December 11, 2024. TEI's comments included recommending additional transactions be included in the recurring transfer group election under the proposed regulations, making the election available when companies use net value computations, and exempting CFCs from application of section 987(3). TEI's comments were prepared under the aegis of its U.S. International Tax Committee and Tax Reform Tas Force. Benjamin Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.
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