25 February 2026 IRS provides guidance for determining foreign currency gain and loss of qualified business units under IRC Section 987 The IRS on February 25, 2026, in Notice 2026-17 (Notice), announced forthcoming proposed regulations that would allow taxpayers to elect to use the equity and basis pool method for calculating unrecognized IRC Section 987 gain or loss and simplify rules related to the final IRC Section 987 regulations published in December 2024 (see Tax Alert 2024-2298). The proposed regulations would also allow controlled foreign corporations (CFCs) to elect not to compute or recognize foreign currency gain or loss except in connection with inbound transactions. A Tax Alert is forthcoming.
Document ID: 2026-0514 | ||
