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- Title
Code Sec. 987 Proposed Regulations--A Choose-Your-Own-Adventure Experience (with a Surprise Ending for Some QBUs).
- Authors
Jenn, Brian
- Abstract
The article focuses on proposed regulations for addressing gain or loss in qualified business units (QBUs) with a different functional currency. It covers key elections like the Current Rate Election and Annual Recognition Election, along with transition rules. It is reported that the regulations aim to simplify calculations but pose potential challenges, especially regarding pre-transition Code Sec. 987 gain or loss.
- Subjects
QUALIFIED business unit; TRANSITION rules; ELECTIONS; DELEGATED legislation; HARD currencies
- Publication
International Tax Journal, 2023, Vol 49, Issue 6, p3
- ISSN
0097-7314
- Publication type
Article