IRS Plans to Propose Currency Gain, Loss Tax Guidance by Summer

May 8, 2026, 7:05 PM UTC

The IRS and Treasury Department hope to release by this summer highly anticipated proposed rules on changes to the tax treatment of currency gains and losses, a Treasury official said.

The agency said in a February notice that it would propose tweaks to regulations under Section 987 on how companies’ subsidiaries treat foreign-currency gains and losses with the intention of reducing regulatory burden on taxpayers and simplifying how the rules operate.

The summer guidance would be limited to the controlled foreign corporation election, Treasury Department International Tax Counsel Jim Wang said.

“We are working very hard to get ...

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