The IRS this week issued new proposed regulations that limit or modify taxpayers' ability to make or revoke certain foreign currency elections. The proposed rules, under IRC Sections 954 and 988, would partially withdraw and modify proposed regulations from 2017 to promote consistency with other filing requirements for controlled foreign corporations (CFCs) and limit taxpayers' ability to make and revoke certain elections related to foreign currency gains or losses.Treasury and the IRS specifically noted that the rules for making and revoking a Prop. Reg. Section 1.988-7 election under the 2017 Proposed Regulations provided an excessive amount of flexibility to taxpayers....