On March 7, 2017, TEI filed comments with the IRS regarding final, proposed, and temporary regulations addressing the recognition foreign currency gain of qualified business units under section 987. The Institute’s comments focused on the administrative and compliance complexity of the regulations, the costs taxpayers must incur to comply with the rules, the potential elimination of the recognition of economic losses, and the lack of adjustments available to taxpayers under section 481 upon adoption of the method required by the regulations for calculating foreign currency gain or loss, among other things.
TEI’s comments were prepared under the aegis of the Institute’s U.S. International Tax Committee. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of the Institute’s comments.