26 U.S.C. § 989
Section 989 · Other definitions and special rules
Current version, with additions and removals from the August 20, 1996 version.
For purposes of this subpart, the term “qualified business unit” means any separate and clearly identified unit of a trade or business of a taxpayer which maintains separate books and records.
For purposes of this subpart, the term “qualified business unit” means any separate and clearly identified unit of a trade or business of a taxpayer which maintains separate books and records.
Except as provided in regulations, for purposes of this subpart, the term “appropriate exchange rate” means—
Except as provided in regulations, for purposes of this subpart, the term “appropriate exchange rate” means—
(1) in the case of an actual distribution of earnings and profits, the spot rate on the date such distribution is included in income,
(1) in the case of an actual distribution of earnings and profits, the spot rate on the date such distribution is included in income,
(2) in the case of an actual or deemed sale or exchange of stock in a foreign corporation treated as a dividend under section 1248, the spot rate on the date the deemed dividend is included in income,
(2) in the case of an actual or deemed sale or exchange of stock in a foreign corporation treated as a dividend under section 1248, the spot rate on the date the deemed dividend is included in income,
For purposes of the preceding sentence, any amount included in income under section 951(a)(1)(B) shall be treated as an actual distribution made on the last day of the taxable year for which such amount was so included.
For purposes of the preceding sentence, any amount included in income under section 951(a)(1)(B) shall be treated as an actual distribution made on the last day of the taxable year for which such amount was so included.
The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this subpart, including regulations—
The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this subpart, including regulations—
(1) setting forth procedures to be followed by taxpayers with qualified business units using a net worth method of accounting before the enactment of this subpart,
(1) setting forth procedures to be followed by taxpayers with qualified business units using a net worth method of accounting before the enactment of this subpart,
(2) limiting the recognition of foreign currency loss on certain remittances from qualified business units,
(2) limiting the recognition of foreign currency loss on certain remittances from qualified business units,
(3) providing for the recharacterization of interest and principal payments with respect to obligations denominated in certain hyperinflationary currencies,
(3) providing for the recharacterization of interest and principal payments with respect to obligations denominated in certain hyperinflationary currencies,
(6) setting forth procedures for determining the average exchange rate for any period.