The US Treasury Department, on December 7, issued final, temporary, and proposed regulations relating to the taxation of foreign currency gains and losses.
The final regulations provide guidance regarding the determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to section 987, and the timing, amount, character, and source of section 987 gain or loss.
The new regulations, which finalize proposed regs issued in September 2006, also amend existing regulations under sections 861, 985, 988, and 989.
Temporary and proposed regulations under section 987, issued the same day, relate to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a QBU in connection with QBU terminations and other transactions involving partnerships.
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** MNE Tax is looking for a tax expert to write a guest article discussing the implications of this development. Please contact us at: [email protected]. **
I don’t understand what percent is the tax going to be