The U.S. IRS has issued Notice 2018-57, which announces an additional one-year delay in the applicability date for final regulations (TD 9794) and temporary regulations (TD 9795), which were published 8 December 2016 and generally effective from 7 December 2016 with a one-year transitional period. The final regulations concern determination of the taxable income or loss of a taxpayer with respect to a qualified business unit (QBU) subject to section 987, as well as the timing, amount, character, and source of any section 987 gain or loss. The temporary regulations concern the recognition and deferral of foreign currency gain or loss under section 987 with respect to a QBU in connection with certain QBU terminations and certain other transactions involving partnerships, as well as certain other issues.
Through Notice 2017-57, issued in October 2017, the regulations were delayed to 1 January 2019 for taxpayers whose first taxable year after 7 December 2016 begins on 1 January 2017. With Notice 2018-57, the final regulations are now delayed to 1 January 2020, although the related temporary regulations will not become applicable because they expire 6 December 2019. Regardless of the delay, however, a taxpayer may apply the final regulations and the related temporary regulations to taxable years beginning after December 7, 2016, provided that they are applied consistently.
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