IRS Prop. Reg.: Income, Currency Gain or Loss with Respect to Qualified Business Units (IRC §987)

Proposed regulations relating to the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit, the IRS released. The following are included: (1) an election to treat all items of a qualified business unit as marked items (subject to a loss suspension rule); (2) an election to recognize all foreign currency gain or loss with respect to a qualified business unit on an annual basis; and (3) a new transition rule. Comments must be received by Feb. 12, 2024. [REG-132422-17, RIN 1545-BO07, 88 Fed. Reg. __ (Nov. 14, 2023)]