The proposed regulations modify the timing within which a foreign currency mark-to-market election can be made or revoked, likely preventing taxpayers from making or revoking a Prop. Treas. Reg. Section 1.988-7 election for the 2023 and 2024 tax years.The proposed regulations align the procedures for making Treas. Reg. Section 1.954-2(g) elections with other elections made on behalf of calendar year and fiscal year CFCs. In newly proposed regulations issued August 19, 2024, under IRC Sections 954 and 988 (the 2024 Proposed Regulations), the Treasury Department and the IRS partially withdrew and modified earlier proposed regulations from 2017 (the 2017 Proposed Regulations)...