Recognition and Deferral of Section 987 Gain or Loss
other · IRS · Rule · Published 2019-05-13 · Effective 2019-05-13 · 84 FR 20790
Document
Document number
2019-09552
Federal Register citation
84 FR 20790
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2019-05-13
Effective date
2019-05-13
Treasury docket
TD 9857
Abstract
This document contains final regulations relating to combinations and separations of qualified business units (QBUs) subject to section 987 and the recognition and deferral of foreign currency gain or loss with respect to a QBU subject to section 987 in connection with certain QBU terminations and certain other transactions involving partnerships. In addition, this document withdraws temporary regulations regarding the allocation of assets and liabilities of certain partnerships for purposes of section 987. The final regulations affect taxpayers that own certain QBUs.