Much uncertainty surrounds the tax health of U.S. businesses under President Trump, in particular, related to the fate of Section 987 regulations.

As discussed in this recent A&M publication by my colleague and partner Al Liguori, the final regulations may benefit taxpayers in specific transactions.

Within 150 days, the Treasury Secretary is directed to prepare a report to the President with recommendations, including advice on whether to delay or suspend Section 987.

Now is the time for tax directors to be re-examining what action they’ve already taken to comply with the final regulations, what gain or loss- triggering events could occur over the next year, and how their conclusions may change if the regulations are eliminated.

A great start is to model the impact of contemplated transactions under the various scenarios the executive order has created.