§ 987. Branch transactions

306 words·~1 min read·/usc/title-26/section-987

A research copy — for the controlling text, always check the official state or federal source. Not legal advice.

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—

(1)by computing the taxable income or loss separately for each such unit in its functional currency,

(2)by translating the income or loss separately computed under paragraph

(1)at the appropriate exchange rate, and

(3)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—

(A)treating post-1986 remittances from each such unit as made on a pro rata basis out of post-1986 accumulated earnings, and

(B)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.

(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.)

Connections36 cite this · traces to 2

Cited by 36 sections · top 6

Traces to 2 documents

U.S. Code

8 references not yet in our index

Pub. L. 99–514, title XII, § 1261(a)
100 Stat. 2586
Pub. L. 100–647, title I, § 1012(v)(1)(B)
102 Stat. 3528
Pub. L. 100–647
Pub. L. 99–514
section 1019(a) of Pub. L. 100–647
section 1261(e) of Pub. L. 99–514

Citation graph

cites case law

§ 987

Branch transactions

Fed. Reg.×36

U.S.C.§ 1

U.S.C.§ 985

Pub. L.Pub. L. 99–514, title XII, § 1261(a)

Stat.100 Stat. 2586

Pub. L.Pub. L. 100–647, title I, § 1012(v)(1)(B)

Stat.102 Stat. 3528

Pub. L.Pub. L. 100–647

Cites 10 · showing 7Cited by 36 across 1 source