The IRS released drafts of the forms and instructions for elections and transition information on how businesses’ subsidiaries treat foreign-currency gains and losses.
The IRS issued a draft of Form 8964-ELE on Section 987 elections and draft instructions, as well as a draft of Form 8964-TRA for Section 987 transition information and draft instructions.
The forms relate to regulations on how “qualified business units”—units of larger companies that do business separately and maintain their own books and records—handle currency transactions and gains and losses in their own taxable income and loss..
Those regulations were finalized in December 2024. ...
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