Finance & markets · 19/12/2017

IRS Proposes New Regulations for Foreign Currency Gain or Loss Related to Business Needs

The IRS has proposed new regulations that provide guidance on the treatment of foreign currency gain or loss of controlled foreign corporations (CFCs) under the business needs exclusion from foreign personal holding company income (FPHCI), allowing taxpayers to use a mark-to-market method of accounting for section 988 transactions.