§987 — Branch transactions
4 cases·4 cited
Statute Text — 26 U.S.C. §987
In the case of any taxpayer having 1 or more qualified business units with a functional currency other than the dollar, taxable income of such taxpayer shall be determined—
by computing the taxable income or loss separately for each such unit in its functional currency,
by translating the income or loss separately computed under paragraph (1) at the appropriate exchange rate, and
by making proper adjustments (as prescribed by the Secretary) for transfers of property between qualified business units of the taxpayer having different functional currencies, including—
treating post-1986 remittances from each such unit as made on a pro rata basis out of post-1986 accumulated earnings, and
treating gain or loss determined under this paragraph as ordinary income or loss, respectively, and sourcing such gain or loss by reference to the source of the income giving rise to post-1986 accumulated earnings.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.987-0 Table of contents
- Treas. Reg. §Treas. Reg. §1.987-0(a) Applicability date of section 987 regulations.
- Treas. Reg. §Treas. Reg. §1.987-0(b) Application of the section 987 regulations to taxable years beginning on or before December 31, 2024, and ending after November 9, 2023.
- Treas. Reg. §Treas. Reg. §1.987-0(c) Application of the 2016 and 2019 section 987 regulations.
- Treas. Reg. §Treas. Reg. §1.987-0(d) Prior § 1.
- Treas. Reg. §Treas. Reg. §1.987-0(e) Examples.
- Treas. Reg. §Treas. Reg. §1.987-0(f) Owner ceases to exist.
- Treas. Reg. §Treas. Reg. §1.987-0(g) Inbound nonrecognition transactions-no carryover of suspended section 987 loss.
- Treas. Reg. §Treas. Reg. §1.987-0(h) Outbound transactions-recognition or suspension of net unrecognized section 987 loss.
- Treas. Reg. §Treas. Reg. §1.987-0(i) Application of § 1.
- Treas. Reg. §Treas. Reg. §1.987-0(j) Termination of a successor suspended loss QBU.
- Treas. Reg. §Treas. Reg. §1.987-0(k) Anti-abuse.
- Treas. Reg. §Treas. Reg. §1.987-0(l) Definitions.
- Treas. Reg. §Treas. Reg. §1.987-0(m) Examples.
- Treas. Reg. §Treas. Reg. §1.987-0(v) Hedge entered into by owner of the hedged QBU.
- Treas. Reg. §Treas. Reg. §1.987-0(x) Example 10: Contribution of a section 987 QBU's assets to a corporation.
- Treas. Reg. §Treas. Reg. §1.987-1 Scope, definitions, and special rules
- Treas. Reg. §Treas. Reg. §1.987-1(a) In general.
- Treas. Reg. §Treas. Reg. §1.987-1(b) Scope of section 987 and certain rules relating to QBUs—(1) Persons subject to section 987—(i) In general.
- Treas. Reg. §Treas. Reg. §1.987-1(c) Exchange rates.
- Treas. Reg. §Treas. Reg. §1.987-1(d) Marked item—(1) In general.
- Treas. Reg. §Treas. Reg. §1.987-1(e) Historic item.
- Treas. Reg. §Treas. Reg. §1.987-1(f) Example: Identification of marked and historic items.
- Treas. Reg. §Treas. Reg. §1.987-1(g) Elections.
- Treas. Reg. §Treas. Reg. §1.987-1(h) Definitions.
4 Citing Cases
4 Century tells us that the basis determinations at issue are central to the computation of a foreign currency translation loss under section 987 that CSC Germany claimed in 2009.
id not abuse his discretion under I.R.C. sec. 482 by reallocating income to P by employing a CPM that used the supply points as the tested parties and the bottlers as the uncontrolled compa- rables. 2. Held, further, R did not err by recomputing P's I.R.C. sec. 987 losses after the CPM changed the income allocable to P's Mexi- can supply point, a branch ofP. 3. Hel_d, further, P made a timely election to employ dividend offset treatment with respect to dividends paid by the supply points during