Issue Number: Notice 2026-17
Inside This Issue
Notice 2026-17 announces the Department of Treasury and the IRS’s intent to issue proposed regulations under section 987 regarding the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit. Specifically, Notice 2026-17 announces forthcoming proposed regulations that would permit taxpayers to elect the equity and basis pool method for the computation of unrecognized section 987 gain or loss, in addition to announcing other simplifying rules related to the final section 987 regulations published in December 2024. Notice 2026-17 further announces forthcoming proposed regulations that would provide an election under which controlled foreign corporations would not compute or recognize foreign currency gain or loss under section 987(3), except in connection with certain inbound transactions.
Notice 2026-17 will be in IRB: 2026-12, dated: March 16, 2026.
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