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United States | Final and proposed regulations on qualified business units retain foreign exchange exposure pool method under Section 987, with simplifying elections

13 December 2024

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Asset Management, Banking & Capital Markets, Legislation & Policy, Global

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United States

Generally applicable to individuals and C corporations (including financial service entities) for tax years beginning after December 31, 2024, but retain special, retroactive applicability date for terminating QBUsInclude several simplifications to the 2023 Proposed Regulations, while retaining the approach and structure of the 2023 Proposed Regulations, including the foreign exchange exposure pool (FEEP) method and current rate and annual recognition electionsProvide additional guidance on eligible pretransition methodsPermit taxpayers that make a current rate election to use certain elements of the earnings and capital method (as described in the 1991 Proposed Regulations) to simplify the computation of unrecognized IRC Section 987...