Finanse publiczne · 08/12/2016

Temporary Regulations on Foreign Currency Gain or Loss Recognition and Deferral under Section 987 of the Internal Revenue Code

The IRS has released temporary regulations under Section 987 of the Internal Revenue Code, providing guidance on the recognition and deferral of foreign currency gain or loss for qualified business units (QBU) in connection with certain terminations and transactions involving partnerships, including rules on deemed termination elections, exchange rate translation, and partnership asset allocation.