26 U.S.C. § 987
Branch transactions
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— (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.
Source: view the official text
Cited by 36
- 26 CFR § 1.1502-13 — Intercompany transactions.
- 26 CFR § 1.1503(d)-0 — Table of contents.
- 26 CFR § 1.1503(d)-5 — Attribution of items and basis adjustments.
- 26 CFR § 1.861-20 — Allocation and apportionment of foreign income taxes.
- 26 CFR § 1.861-9 — Allocation and apportionment of interest expense and rules for asset-based apportionment.
- 26 CFR § 1.861-9T — Allocation and apportionment of interest expense (temporary).
- 26 CFR § 1.904-4 — Separate application of section 904 with respect to certain categories of income.
- 26 CFR § 1.905-3 — Adjustments to U.S. tax liability and to current earnings and profits as a result of a foreign tax redetermination.
- 26 CFR § 1.985-1 — Functional currency.
- 26 CFR § 1.985-5 — Adjustments required upon change in functional currency.
- 26 CFR § 1.985-7 — Adjustments required in connection with a change to DASTM.
- 26 CFR § 1.985-8 — Special rules applicable to the European Monetary Union (conversion to euro).
Show 24 more
- 26 CFR § 1.987-0 — Table of contents.
- 26 CFR § 1.987-1 — Scope, definitions, and special rules.
- 26 CFR § 1.987-10 — Transition rules.
- 26 CFR § 1.987-11 — Suspended section 987 loss relating to certain elections; loss-to-the-extent-of-gain rule.
- 26 CFR § 1.987-12 — Deferral of section 987 gain or loss.
- 26 CFR § 1.987-13 — Suspended section 987 loss upon terminations.
- 26 CFR § 1.987-14 — Section 987 hedging transactions.
- 26 CFR § 1.987-15 — Applicability date.
- 26 CFR § 1.987-2 — Attribution of items to eligible QBUs; definition of a transfer and related rules.
- 26 CFR § 1.987-3 — Determination of section 987 taxable income or loss of an owner of a section 987 QBU.
- 26 CFR § 1.987-3T — Determination of section 987 taxable income or loss of an owner of a section 987 QBU (temporary).
- 26 CFR § 1.987-4 — Determination of net unrecognized section 987 gain or loss of a section 987 QBU.
- 26 CFR § 1.987-5 — Recognition of section 987 gain or loss.
- 26 CFR § 1.987-6 — Character and source of section 987 gain or loss.
- 26 CFR § 1.987-6T — Character and source of section 987 gain or loss (temporary).
- 26 CFR § 1.987-7 — Application of the section 987 regulations to partnerships and S corporations.
- 26 CFR § 1.987-8 — Termination of a section 987 QBU.
- 26 CFR § 1.987-8T — Termination of a section 987 QBU (temporary).
- 26 CFR § 1.987-9 — Recordkeeping requirements.
- 26 CFR § 1.988-0 — Taxation of gain or loss from a section 988 transaction; Table of Contents.
- 26 CFR § 1.988-1 — Certain definitions and special rules.
- 26 CFR § 1.988-1T — Certain definitions and special rules (temporary).
- 26 CFR § 1.988-2T — Recognition and computation of exchange gain or loss (temporary).
- 26 U.S.C. § 856 — Definition of real estate investment trust
Nearby sections (25 sections)
- 961 · Adjustments to basis of stock in controlled foreign corporations…
- 962 · Election by individuals to be subject to tax at corporate rates
- 963 · Repealed. Pub. L. 94–12, title VI, § 602(a)(1), Mar. 29, 1975, 89…
- 964 · Miscellaneous provisions
- 965 · Treatment of deferred foreign income upon transition to…
- 970 · Reduction of subpart F income of export trade corporations
- 971 · Definitions
- 972 · Repealed. Pub. L. 94–455, title XIX, § 1901(a)(120), Oct. 4,…
- 981 · Repealed. Pub. L. 94–455, title X, § 1012(b)(2), Oct. 4, 1976, 90…
- 982 · Admissibility of documentation maintained in foreign countries
- 985 · Functional currency
- 986 · Determination of foreign taxes and foreign corporation’s earnings…
- 987 · Branch transactions
- 988 · Treatment of certain foreign currency transactions
- 989 · Other definitions and special rules
- 991 · Taxation of a domestic international sales corporation
- 992 · Requirements of a domestic international sales corporation
- 993 · Definitions and special rules
- 994 · Inter-company pricing rules
- 995 · Taxation of DISC income to shareholders
- 996 · Rules for allocation in the case of distributions and losses
- 997 · Special subchapter C rules
- 999 · Reports by taxpayers; determinations
- 1000 · Reserved
- 1001 · Determination of amount of and recognition of gain or loss