26 U.S.C. § 987 — Branch transactions
submitted 40 years ago by Pub. L. 99-514 to r/title-26-INTERNAL-REVENUE-CODE · 146 words · no verdicts yet
A translation hasn’t been published for this section yet. The official text below is complete and authoritative.
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.
Source credit: (Added Pub. L. 99–514, title XII, § 1261(a), Oct. 22, 1986, 100 Stat. 2586; amended Pub. L. 100–647, title I, § 1012(v)(1)(B), Nov. 10, 1988, 102 Stat. 3528.)
- 1986Enacted · Pub. L. 99-514 · 100 Stat. 2586
- 1988Amended · Pub. L. 100-647 · 102 Stat. 3528
A history note hasn’t been published yet. The record shows enactment by Pub. L. 99-514 on 1986-10-22.
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