INTERNAL REVENUE SERVICE ISSUES PROPOSED RULE: FOREIGN CURRENCY GAIN OR LOSS OF CONTROLLED FOREIGN CORPORATIONS

WASHINGTON, Aug. 14 -- Internal Revenue Service has issued a proposed rule called: Foreign Currency Gain or Loss of Controlled Foreign Corporations.

The proposed rule was published in the Federal Register on Aug. 14 by Frank J. Bisignano, Chief Executive Officer.

Summary: This document contains proposed regulations providing rules relating to the determination and recognition of foreign currency gain or loss with respect to qualified business units ("QBUs") of controlled foreign corporations ("CFCs"). The proposed regulations provide an election under which a CFC generally would not be required to compute or recognize foreign currency gain or loss upon a remittance from a QBU, except in connection with certain inbound nonrecognition trans...