Treasury Regulations (26 C.F.R.)
26 CFR § 1.986(c)-1
Coordination with section 965.
# (a) Amount of foreign currency gain or loss.
Foreign currency gain or loss with respect to distributions of section 965(a) previously taxed earnings and profits (as defined in § 1.965-1(f)(39)) is determined based on movements in the exchange rate between December 31, 2017, and the time such distributions are made.
# (b) Section 965(a) previously taxed earnings and profits.
Any gain or loss recognized under section 986(c) with respect to distributions of section 965(a) previously taxed earnings and profits is reduced in the same proportion as the reduction by a section 965(c) deduction amount (as defined in § 1.965-1(f)(42)) of the section 965(a) inclusion amount (as defined in § 1.965-1(f)(38)) that gave rise to such section 965(a) previously taxed earnings and profits.
# (c) Section 965(b) previously taxed earnings and profits.
Section 986(c) does not apply with respect to distributions of section 965(b) previously taxed earnings and profits (as defined in § 1.965-1(f)(40)).
# (d) Applicability dates.
The section applies beginning the last taxable year of a foreign corporation that begins before January 1, 2018, and with respect to a United States person, for the taxable year in which or with which such taxable year of the foreign corporation ends.
[T.D. 9846, 84 FR 1915, Feb. 5, 2019]
Source: view the official text
In this part (40 sections)
- 1.965-9 · Applicability dates.
- 1.970-1 · Export trade corporations.
- 1.970-2 · Elections as to date of determining investments in export…
- 1.970-3 · Effective date of subpart G.
- 1.971-1 · Definitions with respect to export trade corporations.
- 1.972-1 · Consolidation of group of export trade corporations.
- 1.981-0 · Repeal of section 981; effective dates.
- 1.981-1 · Foreign law community income for taxable years beginning…
- 1.981-2 · Foreign law community income for taxable years beginning…
- 1.981-3 · Definitions and other special rules.
- 1.985-0 · Outline of regulation.
- 1.985-1 · Functional currency.
- 1.985-2 · Election to use the United States dollar as the functional…
- 1.985-3 · United States dollar approximate separate transactions method.
- 1.985-4 · Method of accounting.
- 1.985-5 · Adjustments required upon change in functional currency.
- 1.985-6 · Transition rules for a QBU that uses the dollar approximate…
- 1.985-7 · Adjustments required in connection with a change to DASTM.
- 1.985-8 · Special rules applicable to the European Monetary Union…
- 1.986(a)-1 · Translation of foreign income taxes for purposes of the…
- 1.986(c)-1 · Coordination with section 965.
- 1.987-0 · Table of contents.
- 1.987-1 · Scope, definitions, and special rules.
- 1.987-2 · Attribution of items to eligible QBUs; definition of a…
- 1.987-3 · Determination of section 987 taxable income or loss of an…
- 1.987-3T · Determination of section 987 taxable income or loss of an…
- 1.987-4 · Determination of net unrecognized section 987 gain or loss of…
- 1.987-5 · Recognition of section 987 gain or loss.
- 1.987-6 · Character and source of section 987 gain or loss.
- 1.987-6T · Character and source of section 987 gain or loss (temporary).
- 1.987-7 · Application of the section 987 regulations to partnerships…
- 1.987-8 · Termination of a section 987 QBU.
- 1.987-8T · Termination of a section 987 QBU (temporary).
- 1.987-9 · Recordkeeping requirements.
- 1.987-10 · Transition rules.
- 1.987-11 · Suspended section 987 loss relating to certain elections;…
- 1.987-12 · Deferral of section 987 gain or loss.
- 1.987-13 · Suspended section 987 loss upon terminations.
- 1.987-14 · Section 987 hedging transactions.
- 1.987-15 · Applicability date.