
Treasury releases final regulations on currency gains and losses of qualified business units
Treasury released final regulations on foreign currency translation gains or losses from QBUs that operate in a different currency than their owner.
A company undergoing a strategic transition (e.g., merger, acquisition, reorganization, divestiture) risks losing value and control. The complexity surrounding the transition can impede a company’s ability to simultaneously focus on maintaining current operations, realizing valuable deal synergies, and achieving timely integration. Companies must focus on cross-border tax planning strategies to help efficiently align their commercial and tax objectives.
PwC’s International Tax Services and Mergers & Acquisitions teams can help your company identify and analyze the potential tax effects of a strategic transition during the planning and implementation stages of a deal, thereby letting you focus on the business opportunities, barriers, and risks associated with the transition.
We can work with you to:
Maintain control of key tax areas during the transitional period
Identify and assess potential business opportunities for tax efficiencies, domestic and foreign
Develop a longer-term tax strategy to improve the group’s tax and cash-flow position
Perform acquisition and vendor due diligence, working closely with PwC’s M&A team
Assist with Treasury related matters such as financing a transaction
Treasury released final regulations on foreign currency translation gains or losses from QBUs that operate in a different currency than their owner.
New prop regs treat members of consolidated group as single US shareholder when CFC stock ownership changes among group members and a CFC makes a distribution.