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Code · U.S. Code · Title 26 - INTERNAL REVENUE CODE · CHAPTER 1— NORMAL TAXES AND SURTAXES · Subchapter N— Tax Based on Income From Sources Within or Without the United States · § 985

§ 985. Functional currency

376 words·~2 min read·/usc/title-26/section-985

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(a)In general Unless otherwise provided in regulations, all determinations under this subtitle shall be made in the taxpayer’s functional currency.
(b)Functional currency
(1)In general For purposes of this subtitle, the term “functional currency” means—
(A)except as provided in subparagraph (B), the dollar, or
(B)in the case of a qualified business unit, the currency of the economic environment in which a significant part of such unit’s activities are conducted and which is used by such unit in keeping its books and records.
(2)Functional currency where activities primarily conducted in dollars The functional currency of any qualified business unit shall be the dollar if activities of such unit are primarily conducted in dollars.
(3)Election To the extent provided in regulations, the taxpayer may elect to use the dollar as the functional currency for any qualified business unit if—
(A)such unit keeps its books and records in dollars, or
(B)the taxpayer uses a method of accounting that approximates a separate transactions method.
Any such election shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.
(4)Change in functional currency treated as a change in method of accounting Any change in the functional currency shall be treated as a change in the taxpayer’s method of accounting for purposes of section 481 under procedures to be established by the Secretary.
(Added Pub. L. 99–514, title XII, § 1261(a), Oct. 22, 1986, 100 Stat. 2585.)
Connections20 cite this
4 references not yet in our index
  • Pub. L. 99–514, title XII, § 1261(a)
  • 100 Stat. 2585
  • Pub. L. 99–514, title XII, § 1261(e)
  • 100 Stat. 2591
Citation graph
cites case law
§ 985
Functional currency
Fed. Reg.×14
U.S.C.×6
Pub. L.Pub. L. 99–514, title XII, § 1261(a)
Stat.100 Stat. 2585
Pub. L.Pub. L. 99–514, title XII, § 1261(e)
Stat.100 Stat. 2591
Cites 4Cited by 20 across 2 sources
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