13 August 2026 Treasury proposes election under which CFCs generally would not compute or recognize IRC Section 987 gain or loss On August 13, 2026, Treasury and the IRS released proposed regulations (REG-103844-26) under IRC Section 987 that would permit controlled foreign corporations to elect out of rules requiring them to compute or recognize IRC Section 987 gain or loss from their qualified business units, except for certain inbound nonrecognition transactions. Taxpayers may rely on the proposed regulations for tax years beginning after December 31, 2024, subject to the applicable consistency requirements. A Tax Alert is forthcoming.
Document ID: 2026-1742 | ||
