Internal Revenue Service December 27, 2017 – Federal Register Recent Federal Regulation Documents

Exclusion of Foreign Currency Gain or Loss Related to Business Needs From Foreign Personal Holding Company Income; Mark-to-Market Method of Accounting for Section 988 Transactions; Correction
Document Number: 2017-27865
Type: Proposed Rule
Date: 2017-12-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to the proposed regulations (REG-119514-15) that were published in the Federal Register on Tuesday, December 19, 2017. The proposed regulations provide guidance on the treatment of foreign currency gain or loss of a controlled foreign corporation (CFC) under the business needs exclusion from foreign personal holding company income (FPHCI). The proposed regulations also provide an election for a taxpayer to use a mark-to-market method of accounting for foreign currency gain or loss attributable to section 988 transactions. In addition, the proposed regulations permit the controlling United States shareholders of a CFC to automatically revoke certain elections concerning the treatment of foreign currency gain or loss.
Treatment of Transactions in Which Federal Financial Assistance Is Provided; Correction
Document Number: 2017-27863
Type: Rule
Date: 2017-12-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance is provided to banks and domestic building and loan associations, and they clarify the federal income tax consequences of those transactions to banks, domestic building and loan associations, and related parties.
Treatment of Transactions in Which Federal Financial Assistance Is Provided; Correction
Document Number: 2017-27862
Type: Rule
Date: 2017-12-27
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to final regulations (TD 9825) that were published in the Federal Register on Thursday, October 19, 2017. The final regulations are under section 597 of the Internal Revenue Code. These final regulations amend existing regulations that address the federal income tax treatment of transactions in which federal financial assistance is provided to banks and domestic building and loan associations, and they clarify the federal income tax consequences of those transactions to banks, domestic building and loan associations, and related parties.