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NEW IRS Foreign Currency GuidanceNotice 2017-07

rocky
rocky
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Post by rocky on Fri 23 Dec 2016, 6:10 am

First topic message reminder :


NEW IRS Foreign Currency Guidance
Notice 2017-07
 




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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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Tiffany
Tiffany
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Post by Tiffany on Fri 23 Dec 2016, 11:18 pm

Ha! I'm cracking up because there was a time when I was worried that I wouldn't make the Long-term Capital Gains timeframe!  laugh  funny laugh 
....pretty sure I'm safe!  lol!
tongue
Neno
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Post by Neno on Fri 23 Dec 2016, 11:58 pm

[You must be registered and logged in to see this link.] wrote:with 2 hours sleep my brian isn't working , so what dose that mean for us Neno
lol....seriously..lol All I can say is it must be serious and in a rush!
ahill
ahill
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Post by ahill on Sat 24 Dec 2016, 1:18 am

Wow!
Good news keeps coming everyday -  thankx a bunch to all our news hounds.
Without you I'd be lost.
Come on we're liking you ... RV      bounce
Screwball
Screwball
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Post by Screwball on Sat 24 Dec 2016, 2:02 am

[You must be registered and logged in to see this link.] wrote:
[You must be registered and logged in to see this link.] wrote:with 2 hours sleep my brian isn't working , so what dose that mean for us Neno
lol....seriously..lol All I can say is it must be serious and in a rush!
Yeah it's all about timing....
Readytogo
Readytogo
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Post by Readytogo on Sun 25 Dec 2016, 10:35 am

I'm also excited about the timing!  I'm feeling a little dumb and lazy but gonna ask anyways, what has changed on the taxation of exchanging?  Is it Only the time limit of long vs short term gains?  Ward's contribution is very interesting, thanks Ward and Rocky!
Neno
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Post by Neno on Sun 25 Dec 2016, 6:13 pm

[You must be registered and logged in to see this link.] wrote:I'm also excited about the timing!  I'm feeling a little dumb and lazy but gonna ask anyways, what has changed on the taxation of exchanging?  Is it Only the time limit of long vs short term gains?  Ward's contribution is very interesting, thanks Ward and Rocky!
I think it is just the attention being given to it in a time many think we are right there... including me.

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