On 8 December 2016, final regulations (TD 9794) were published in the U.S. Federal Register that provide guidance under section 987 of the Internal Revenue Code (Code) regarding the determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to section 987, as well as the timing, amount, character, and source of any section 987 gain or loss. Taxpayers affected by these regulations are corporations and individuals that own QBUs subject to section 987. Also published on 8 December are temporary regulations (TD 9795) under section 987 of the Code relating...