The U.S. IRS has published a practice unit on Limitation of Exchange Gain or Loss on Payment or Disposition of Debt Instrument. The general overview of the practice unit is as follows: The determination of foreign currency (FX) gains and losses under IRC Section 988 is one of the major strategic priorities for the Foreign Currency Practice Network (PN) on the Crossover portion of the International Matrix. In a global economy, many U.S. Multinational Enterprises (MNEs) are doing business in currencies other than the U.S. dollar (USD). These transactions may be one-time transactions (e.g., a loan denominated in an FX),...