Proposed regulations under IRC Section 987 generally retain, with certain modifications, regulations that were finalized in 2016 and 2019.The proposed regulations allow taxpayers to make various simplifying elections to ease compliance burdens, but may result in loss deferral and limit the taxpayer's ability to control the timing of IRC Section 987 losses.The proposed regulations would apply to tax years beginning after December 31, 2024, with a new transition rule that depends on whether and how taxpayers complied with IRC Section 987.The proposed regulations would limit taxpayers' ability to recognize IRC Section 987 losses from terminations of qualified business units on...