AICPA Comments on IRS Currency Transaction Proposal

The Institute’s tax executive committee submitted recommendations on IRS-proposed revisions to section 987 of the Internal Revenue Code that require a taxpayer to recognize exchange gain or loss—upon receiving a remittance from a qualified business unit (QBU)—by apportioning its basis in the QBU to each remittance and then recognizing exchange gain or loss based on the difference between the value of the remittance and the basis apportioned to it ( www.cpa2biz.com/ResourceCenters/Tax/International/987regs.htm ). Among its other suggestions, the committee recommended the revised regulations provide that no exchange gain or loss be recognized on remittances of capital from a QBU and that they adopt the “four-pool” approach of regulations section 1.987-5 to determine whether transfers are remittances of earnings or capital.