Treasury Plans to Revisit Final Rules on Currency Gains, Losses

December 11, 2025, 7:47 PM UTC

The Treasury Department will reevaluate regulations finalized during the Biden administration that detail how companies should treat their subsidiaries’ foreign currency gains and losses, a top department official said.

The final regulations under Section 987 “make sense in a lot of ways” on an intellectual level, but sometimes an “academically pure, theoretical structure doesn’t play out well in the real world with actual tax departments,” said Kevin Salinger, deputy assistant secretary for tax policy at Treasury.

He spoke at the US branch of the International Fiscal Association’s 6th Annual Virtual International Tax Conference on Thursday.

The final regulations released ...

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