Foreign exchange gain or loss is a feature of most cross-border business activity and has tax implications under two different sets of rules governing foreign currency transactions (§ 988) and foreign ...

The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or ...

A perplexing attribute of the U.S. tax system is that successive reform efforts tend to layer new regimes on top of old ones without bothering to repeal the latter. It’s as if retention of the older ...