The U.S. IRS has issued Notice 2018-57, which announces an additional one-year delay in the applicability date for final regulations (TD 9794) and temporary regulations (TD 9795), which were published 8 December 2016 and generally effective from 7 December 2016 with a one-year transitional period. The final regulations concern 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. The temporary regulations concern the recognition and deferral of foreign currency gain or...