Home
First topic message reminder :
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).
[You must be registered and logged in to see this link.]
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).
[You must be registered and logged in to see this link.]
» Kuwait is drilling an oil well near Umm Qasr, towards Iraqi territory
» In the document... the first Iraqi ministry identifies the obstacles to changing the new official wo
» Italian Institute: Iraq is stuck in its own crises, including Baghdad’s efforts to undermine the “au
» The head of the Integrity Commission announces the holding of an international Interpol conference i
» Planning: Iraqi companies are not efficient in conducting the population census
» utube MM&C 4/24/24 Support - USA- Turkey - Timing- Currency Value - Tabled
» MM&C 4/25/24 National Bank of Iraq goes live with Temenos core banking and payments
» utube MM&C 4/26/24 Iraqi Dinar - US Treasury Exchange Rates- Focus - Banking Partnerships - Rate C
» A banking official indicates a "danger" to Iraq by depriving more than half of its banks of dollars
» With the participation of the Association of Private Banks, investment opportunities are on the tabl
» Within a month... an Iranian border crossing recorded a noticeable increase in exports of goods to I
» The Association of Private Banks appreciates the efforts of the government and the Central Bank to c
» Al-Maliki's coalition presents a third candidate for the position of governor of Diyala
» Arab gathering: The Kirkuk problem is getting complicated and the Sudanese must intervene
» Next week.. a Kurdish delegation will visit Baghdad to meet with the Minister of Finance
» Under the pretext of salaries... Al-Party refrains from handing over port revenues to Baghdad
» Association of Banks: For the first time, we are witnessing a clear targeting of depriving half of t
» Parliament does not know the reason for the delay in sending the 2024 budget schedules: Voting takes
» Applicants for the 2024 Hajj are demanding that the Central Bank secure the dollar for them through
» Governmental and private banks will showcase their services tomorrow during Financial Inclusion Week
» Iraq's oil exports rise despite OPEC+ cuts
» A study explodes a "surprise"... Iraq is among the countries that export oil to "Israel": How is the
» Al-Araji emphasizes working to strengthen national identity
» Al-Sudani visits Saudi Arabia to participate in the World Economic Forum in Riyadh
» Iraq is talking about producing one million additional liters of gasoline
» The Council of Ministers approves the implementation of the Baghdad Metro project
» Minister of Commerce: We formed a joint economic committee with Türkiye
» Resources: Government measures have contributed to improving the water situation in Iraq
» Parliamentary Finance: Baghdad will continue to send salaries to the region’s employees until settle
» A parliamentarian describes the corruption of Iraqi ports as “ghouls” and reveals the involvement of
» Obelisk Hour: Basra is the subject of political conflict and ambiguity over the fate of the funds al
» Turkmen leader: An agreement on the local government of Kirkuk is near
» Anbar calls for the operation of its factories despite financial obstacles
» Turki: The crisis of the Presidency of Parliament prompted the Sunnis to amend the Council’s interna
» The Agriculture Committee confirms the existence of Iraqi-Turkish-Iranian discussions on water
» Resources diagnose the challenges facing the water file in Iraq
» Parliament pledges to the Interior Ministry: We will transfer money to buy weapons from citizens
» Al-Issawi is the closest.. Parliament sets the date for deciding the choice of the new president
» Deputy: Iraq's investments have risen and need a comprehensive review of previous years
» Iraqis consume 7 billion eggs annually and import about $900 million
» The Iranian role complicates attempts at open cooperation between Iraq and Turkey. Turkey is trying
» Move in Iran to obtain $242 billion from Iraq in compensation for the eight-year war
» 12 decisions from the Council of Ministers regarding the Baghdad Metro and Najaf-Karbala train proje
» Sudanese Advisor: The path to development has begun... the Baka and the militias “we silence them wi
» Not from Kurdistan.. How did Iraq become a source of oil for “Israeli tanks”?
» Parliamentary Agriculture criticizes the Sudanese and Erdogan agreement: Türkiye will control water
» The Iraqi government issues new decisions
» The story of “reduced oil” to Jordan, from “compulsion” to mutual benefit.. Is there a loss?
» The Council of Ministers takes 12 decisions for the Baghdad Metro and the Najaf-Karbala train
» utube MM&C 4/23/24 Iraqi Dinar - IQD Update - Development Road Project - Saviour of Global Banking
» Kidney from pig transplanted into deathly ill New Jersey woman — and begins working almost immediat
» The most difficult option.. Warnings of the danger of floating the Iraqi dinar without achieving an
» Trade from the “Economic Committee” with Türkiye: It will overcome all obstacles facing the traders
» Washington's hope for stable relations with Baghdad clashes with Iraqi parties' rejection of the Ame
» Karim Badr: Development is America’s will to kill silk
» Oil: Opening of a new port for liquid gas for vehicles in Baghdad
» A media advisor warns of corruption in a draft law on the Parliament’s agenda
» Economist: There is serious work to lift US sanctions on Iraqi banks
» Will the agreements signed with the US Treasury reflect positively on the exchange rates?
» Iraq continues its quest to join the World Trade Organization
» Iraq completes the completion of the files for the initial offer of goods and services to join the W
» Economist: Travelers' dollars are leaking into the parallel market...and this is what the Central Ba
» President of the Federal Court: It is not permissible to force anyone to join any party, and the pol
» The Council of Ministers holds its session headed by Al-Sudani
» America weakens Baghdad...and increases Kurdistan's military capabilities
» The Iraqi government plans to build 10,000 schools throughout the country
» American threats close the Iraqi Stock Exchange at a loss
» Increase in external transfers at the Central Bank
» Al-Maliki calls on Britain to cancel restrictions on the entry of its companies into Iraq
» Planning and the European Union are discussing signing a number of agreements in the development, en
» Parliament talks about the mechanism for recovering smuggled funds and hints at the next stage
» Interior Ministry: The number of completed national cards reached 37 million cards
» Amnesty International: Violations of freedom and human rights continue in Iraq and the Kurdistan Reg
» Parliamentary Oil: The government is proceeding with the decision to raise the price of improved gas
» A parliamentary committee in Basra to investigate violations of the port company and the local gover
» Revealing the 10 most important American exports to Iraq
» A noticeable increase in the rate of Iraq's import of Chinese cooling devices
» Prime Minister: Working on projects without completing the infrastructure is a waste of money
» Iraq.. Extending the deadline for registration procedures on plots of land
» What is the main purpose of conducting the population census in Iraq?
» A plan to transform Iraq from a barren land to green with 5 million trees
» The Housing Fund announces the acceptance of more than 11 thousand loans through the Ur platform
» The Bank of Baghdad is moving to increase its capital to 400 billion dinars
» The electronic payment system will soon be adopted on Iraqi buses
» “It threatens our interests and destroys our economy.” An Iraqi project “irritates” the Kuwaiti stre
» Warning from the Central Bank about “misuse of electronic payment cards”
» Iraq and the Sultanate of Oman are discussing sending capacities through the Gulf countries
» The fact that a decision was issued to deport Syrian workers from Iraq
» Rice comes first... America exports 10 foodstuffs worth more than 350 million dollars to Iraq
» A sixth licensing round for gas exploration
» Baghdad is preparing to host the 50th session of the Arab Labor Conference
» Scientific symposium on the future vision of the tripartite budget
» Five conversion power stations enter service in Najaf
» Planning: Conduct a population census next November
» Experts: Spreading misleading information harms development and investment
» Economists call for tightening money laundering laws and port controls
» Today's newspapers are interested in Sudanese's visit to Anbar Governorate and preparations for cond
» Iraq and Russia discuss cooperation between the two countries in the field of information and artifi