On April 24, 2026, TEI submitted comments on Notice 2026-17, which announced the Government's intention to issue proposed regulations under section 987. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the letter. The comments addressed timing and procedural guidance for the CFC election, how to compute and recognize the section 987 basis increase related to certain inbound transactions, and revisions for the remittance proportion formula for the equity and basis pool method.
Read the Comments Here
Committee