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Neno's Place Established in 2006 as a Community of Reality


Neno

I can be reached by phone or text 8am-7pm cst 972-768-9772 or, once joining the board I can be reached by a (PM) Private Message.

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Established in 2006 as a Community of Reality

Welcome to the Neno's Place!

Neno's Place Established in 2006 as a Community of Reality


Neno

I can be reached by phone or text 8am-7pm cst 972-768-9772 or, once joining the board I can be reached by a (PM) Private Message.

Established in 2006 as a Community of Reality

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Established in 2006 as a Community of Reality

Many Topics Including The Oldest Dinar Community. Copyright © 2006-2020


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    NEW IRS Foreign Currency GuidanceNotice 2017-07

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    Post by Rocky Fri 23 Dec 2016, 6:10 am


    NEW IRS Foreign Currency Guidance
    Notice 2017-07
     




    [You must be registered and logged in to see this link.]
    Foreign currency guidance under section 987
    Notice 2017-07
    On December 7, 2016, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) filed with the Federal Register Treasury Decision 9795, which includes temporary regulations under §1.987-12T relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit in connection with a deferral event or outbound loss event. Section 1.987-12T(j)(1) provides that §1.987-12T generally applies to any deferral event or outbound loss event that occurs on or after January 6, 2017. Under §1.987-12T(j)(2), however, §1.987-12T also applies to any deferral event or outbound loss event that occurs on or after December 7, 2016, if such deferral event or outbound loss event is undertaken with a principal purpose of recognizing section 987 gain or loss.
    In order to prevent abuse, §1.987-12T(j)(2) will be modified so that §1.987-12T also will apply to any deferral event or outbound loss event that is undertaken with a principal purpose of recognizing section 987 gain or loss and that occurs as a result of an entity classification election made under §301.7701-3 that is filed on or after December 22, 2016, and that is effective before December 7, 2016. Additionally, §1.987-12T(j)(1) will be modified so that §1.987-12T also will apply to any deferral event
    or outbound loss event that occurs as a result of an entity classification election made under §301.7701-3 that is filed on or after January 6, 2017, and that is effective before January 6, 2017.
    The principal author of this notice is Steven D. Jensen of the Office of Associate Chief Counsel (International). However, other personnel from the Treasury Department and the IRS participated in its development. For further information regarding this notice contact Steven D. Jensen at (202) 317-6938 (not a toll-free call).


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    Post by Rocky Fri 23 Dec 2016, 6:13 am

    the fact that they are doing this RIGHT NOW is pretty ding-dang exciting, if you ask me........
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    Post by BILLYB Fri 23 Dec 2016, 6:26 am

    with 2 hours sleep my brian isn't working , so what dose that mean for us Neno
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    Post by Preacher Man Fri 23 Dec 2016, 6:27 am

    rocky wrote:the fact that they are doing this RIGHT NOW is pretty ding-dang exciting, if you ask me........
    rocky, I dont post much, but wanted to tell-you Thanks,
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    Post by weslin3 Fri 23 Dec 2016, 8:01 am

    rocky wrote:the fact that they are doing this RIGHT NOW is pretty ding-dang exciting, if you ask me........
    Dance banna2 banna3 drunk bounce duck

    I totally agree rocky!!
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    Post by sassy Fri 23 Dec 2016, 8:08 am

    duck Magic 8 Ball yes
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    Post by wciappetta Fri 23 Dec 2016, 8:27 am

    In case anyone is wondering....

    Foreign currency bank account: when and how is the exchange rate appreciation taxed by the IRS?

    Is appreciation taxed annually or only when converted back into USD? Ordinary income, short-term capital gains, long-term capital gains?

    (non-interest bearing personal bank account not used for business purposes or investment purposes)


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    [You must be registered and logged in to see this link.]Software Tester, Tax Advisor and Analyst, Baseball Think Factory writer

    Studied at Carnegie Mellon University

    Lives in Phoenix, AZ

     

    [You must be registered and logged in to see this link.], 20+ years of preparing taxes

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    The IRS draws a distinction between personal transactions and business transactions, so we only have to look at personal transactions for this question. For personal (non-business) transactions, if you have a gain from a foreign currency transaction you do not include it in income unless it exceeds $200, then you report it as capital gain. If you have a loss, you can't deduct it; personal losses are non-deductible. See [You must be registered and logged in to see this link.].
     
    Bear in mind that you only have a reportable event when you have a foreign currency
    transaction - if you have an account in Italy that is denominated in Euros, and you withdraw money from that account to pay a bill that is also denominated in Euros, you don't have a foreign currency transaction. But if you withdraw from that account to pay a bill (or do a wire transfer to a US-based account) that is denominated in US dollars, you do.
     
    You also don't have any exchange-rate appreciation on a one-way transaction. If you made a deposit into your account in Italy in Euros and then withdrew and converted it to US dollars, there's no effect. If you originally converted US dollars to Euros, made a deposit to your Italian bank account, and then withdrew Euros for use in Italy, you also have no exchange-rate impact. But if you converted from US dollars to deposit, and then convert back to US dollars after withdrawal, then the exchange rate comes into play.


     

     

     

     

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    [You must be registered and logged in to see this link.]In the beginning was the Word, and the Word was with God, and the Word was God.... For from His fullness, we have all received and grace upon grace. For the Law was given through Moses; grace and truth came through Jesus Christ. No one has ever yet seen God. The only begotten God, the One being in the bosom of the Father, He has made Him known. - Berean Literal Bible
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    Post by Rocky Fri 23 Dec 2016, 9:11 am

    good stuff thanks Ward
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    Post by weslin3 Fri 23 Dec 2016, 10:32 am

    Ward thanks for helping me on this... I liked it that they were doing something with the timing of all else but didn't understand it. lol
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    Post by Lobo Fri 23 Dec 2016, 12:51 pm

    WOW, Rocky and Ward, thanks - this is very exciting following on the IMF news about the 2017 budget, etc.

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