NEW IRS Foreign Currency Guidance

[fnbplanet]

Foreign currency guidance under section 987
Notice 2017-07
On December 7, 2016, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) filed with the Federal Register Treasury Decision 9795, which includes temporary regulations under §1.987-12T relating to the recognition and deferral of foreign currency gain or loss under section 987 with respect to a qualified business unit in connection with a deferral event or outbound loss event. Section 1.987-12T(j)(1) provides that §1.987-12T generally applies to any deferral event or outbound loss event that occurs on or after January 6, 2017. Under §1.987-12T(j)(2), however, §1.987-12T also applies to any deferral event or outbound loss event that occurs on or after December 7, 2016, if such deferral event or outbound loss event is undertaken with a principal purpose of recognizing section 987 gain or loss.
In order to prevent abuse, §1.987-12T(j)(2) will be modified so that §1.987-12T also will apply to any deferral event or outbound loss event that is undertaken with a principal purpose of recognizing section 987 gain or loss and that occurs as a result of an entity classification election made under §301.7701-3 that is filed on or after December 22, 2016, and that is effective before December 7, 2016. Additionally, §1.987-12T(j)(1) will be modified so that §1.987-12T also will apply to any deferral event
or outbound loss event that occurs as a result of an entity classification election made under §301.7701-3 that is filed on or after January 6, 2017, and that is effective before January 6, 2017.
The principal author of this notice is Steven D. Jensen of the Office of Associate Chief Counsel (International). However, other personnel from the Treasury Department and the IRS participated in its development. For further information regarding this notice contact Steven D. Jensen at (202) 317-6938 (not a toll-free call).

 

Link

[429]

I think that all of that is in English but can someone dumb it down for me?

[fnbplanet]

But wait....there's More!

150 pages of section 987:

section 987 150 pages

[TexasMike1958]

I think what it means is...  After the RV when you cash in, the IRS will let you keep it all and not take any of our windfall for taxes.  Is that what it sounds like to you??? 

[fnbplanet]

I'm trying to track all of this down, as I just received this IRS bulletin minutes ago.  It sound as if they're tweaking/clarifying their previous rules on profit/loss from foreign currency transactions.

 

On one hand, they will want their "share".

On the other hand, the fact that they are doing this RIGHT NOW is pretty ding-dang exciting, if you ask me........

[Boozer]

5 minutes ago, TexasMike1958 said:

I think what it means is...  After the RV when you cash in, the IRS will let you keep it all and not take any of our windfall for taxes.  Is that what it sounds like to you??? 

I like the way you thinks. But not sure the tax man will

[bostonangler]

I tried to read this the other day and from what I could tell a lot of it has to do with corporate income and taxes. There was a lot about gains and losses based on price of products and services from currency to currency. But in reality, we would need a tax lawyer to explain it. I'm not sure if any of what I read had to do with personal exchanges.

 

B/A

[fnbplanet]

It does sound like it's for corporations and those with foreign business units:

"These regulations are necessary to provide guidance under section 987. Taxpayers affected
by these regulations are corporations and individuals with qualified business units
subject to section 987."

I have to admit that the fact that there's movement by the IRS to further clarify ANYTHING to do with profit from foreign currency transactions, at this time, gets me a bit pumped!

[jeepguy]

The date time lines ,. Is sure suspect ,  Almost like a window in which currency might make a move in which some happy or not happy folks will be in a different tax bracket ....  And if I remember right isn't  10,ooo  the marker number the internal revenue kick s  in?   All the news on banking  and now this 

[four wheel drift]

Issued this year for this year's changes?

8 more days left in the year.

HOPIUM

FWD

GO RV

[Freedomwish]

Hey, if the IRS are planning to make some moves now, tells me and gives me hope that the RV is indeed very near!  

[Shedagal]

My thoughts on the rest of this year . . . first of all, I've always thought it would show up at the open of the CBI's business day (8 a.m. their time; around midnight our time - depending on daylight savings).  It didn't happen today.  The CBI will be closed Friday and Saturday.  Next seemingly possible time is midnight Sat. - wouldn't that be a heck of a Christmas text from Adam!!!  Then we have Sun-Thurs. of next week.  This is the window I see for the rest of the year.

[10 YEARS LATER]

Some days it's like shooting Craps with the guys - All we need is just one more soft and sultry breeze to caress those Lucky Dice - Roll those Bones Baby.

The only way the "Dealer" (Iraq) gets paid, is if folks ( us ) are winning ! It would be Oh so Great to WIN !

[SgtFuryUSCZ]

2 hours ago, TexasMike1958 said:

I think what it means is...  After the RV when you cash in, the IRS will let you keep it all and not take any of our windfall for taxes.  Is that what it sounds like to you??? 

***///  Nobody will "cash in".... it will be a simple 'Currency Exchange'.

What, if any, penalties/action the IRS decides to take against any person receiving an unusually high rate of exchange 'windfall'

remains to be seen, as this is not an "investment" in the traditional sense - which the IRS just loves to pounce on ya for.

It is merely folks who have currency from another country on hand and wish to convert it to the country of their choice's currency.

Just our opinion --- we'll see.....

Now if you voted for Trump, or are a Tea Party member and ho'bummer's henchmen are still entrenched at the IRS,

well, we can all bend over and kiss our "exchange windfalls" goodbye.

[fnbplanet]

When you toast your friends and relatives during this joyful season, be sure to thank Mr. Trump for his future rollback of the Capital Gains Tax AND the rollback of the inheritance tax.

 

Table 1. Individual Income Tax Brackets Under Donald Trump’s Tax Plan
Ordinary Income	Capital Gains and Dividends	Single Filers	Married Filers	Head of Household
0%	0%	$0 to $25,000	$0 to $50,000	$0 to $37,500
10%	0%	$25,000 to $50,000	$50,000 to $100,000	$37,500 to $75,000
20%	15%	$50,000 to $150,000	$100,000 to $300,000	$75,000 to $225,000
25%	20%	$150,000 and up	$300,000 and up	$225,000 and up

 

Just sayin'........

 

(of course, see a professional tax expert, but feel free to dream about whatever your heart desires!)

[MyLadiesDaddy]

1 hour ago, fnbplanet said:

I'm trying to track all of this down, as I just received this IRS bulletin minutes ago.  It sound as if they're tweaking/clarifying their previous rules on profit/loss from foreign currency transactions.

 

On one hand, they will want their "share".

On the other hand, the fact that they are doing this RIGHT NOW is pretty ding-dang exciting, if you ask me........

More than that, notice how Obummers is signing Executive Orders like there's no tomorrow. He's doing that because he's   just stupid enough to think that he's backing Trump in some kind of corner. What the likes of him and John,"the loser", McCain don't understand is that Trump is not a politician. He's not going to play their games because he doesn't know how to, and he seemingly doesn't know how to lose either.

Having said that I believe that most of what we're seeing lately is what some here have called, " The Trump Effect". And I believe that is also why we're seeing so much rapid movement in Iraq. At this point I can't help but think that the very reason a successful billionaire did whatever it took to be President has more to do with his own investment in Iraq than anything else. Not to forget that he will do wonderful things for America after he turns the trillions of dinar that our Treasury Department bought in the beginning of all this into trillions of dollars.  People like Obummer and loser career politicians  simply don't understand what is coming. Janet ,"bimbo", Yellin raises interest rates and promises to keep doing so. Why? Because she thinks that will destroy a Trump Presidency by damaging our economy. But the bimbo doesn't understand that Donald Trump will be able to wipe out every single dollar of debt that Obummers created in one single day with the RV of the Iraqi dinar. 

What do you all think that will do for our economy and for Donald Trump? 

Prez Obummer thinks that he can stay in Washington and use the LSM to destroy Donald Trump but he and the LSM will only be pi$$ing into the wind. Donald Trump has shown clearly that he doesn't need them and that he knows how to go around them. What do you all think his,"Thank You Tour", is? Not to mention his Tweets. This man is a tank and the evil, baby killing, libertards have good justification to be scared. He's going to destroy the morons in our nation.  

[precious1]

Thanks fnb, indeed Interesting tidbits, this time of year. Merry Christmas one and all!

[psdon]

Go Trump Go RV  

[Shedagal]

24 minutes ago, fnbplanet said:

When you toast your friends and relatives during this joyful season, be sure to thank Mr. Trump for his future rollback of the Capital Gains Tax AND the rollback of the inheritance tax.

 

Table 1. Individual Income Tax Brackets Under Donald Trump’s Tax Plan
Ordinary Income	Capital Gains and Dividends	Single Filers	Married Filers	Head of Household
0%	0%	$0 to $25,000	$0 to $50,000	$0 to $37,500
10%	0%	$25,000 to $50,000	$50,000 to $100,000	$37,500 to $75,000
20%	15%	$50,000 to $150,000	$100,000 to $300,000	$75,000 to $225,000
25%	20%	$150,000 and up	$300,000 and up	$225,000 and up

 

Just sayin'........

 

(of course, see a professional tax expert, but feel free to dream about whatever your heart desires!)

Thanks for posting this.  I definitely think things tax-wise will be better under Trump's plan.  But it has been discussed here for a while and generally accepted that our gain will be ordinary income.  As stated by you, we will need to seek professional expertise at time of RV.  Not trying to get into debate about tax matters; just want use to be informed as much as we can.

[Monkndad]

16 minutes ago, ladyGrace'sDaddy said:

More than that, notice how Obummers is signing Executive Orders like there's no tomorrow. He's doing that because he's   just stupid enough to think that he's backing Trump in some kind of corner. What the likes of him and John,"the loser", McCain don't understand is that Trump is not a politician. He's not going to play their games because he doesn't know how to, and he seemingly doesn't know how to lose either.

Having said that I believe that most of what we're seeing lately is what some here have called, " The Trump Effect". And I believe that is also why we're seeing so much rapid movement in Iraq. At this point I can't help but think that the very reason a successful billionaire did whatever it took to be President has more to do with his own investment in Iraq than anything else. Not to forget that he will do wonderful things for America after he turns the trillions of dinar that our Treasury Department bought in the beginning of all this into trillions of dollars.  People like Obummer and loser career politicians  simply don't understand what is coming. Janet ,"bimbo", Yellin raises interest rates and promises to keep doing so. Why? Because she thinks that will destroy a Trump Presidency by damaging our economy. But the bimbo doesn't understand that Donald Trump will be able to wipe out every single dollar of debt that Obummers created in one single day with the RV of the Iraqi dinar. 

What do you all think that will do for our economy and for Donald Trump? 

Prez Obummer thinks that he can stay in Washington and use the LSM to destroy Donald Trump but he and the LSM will only be pi$$ing into the wind. Donald Trump has shown clearly that he doesn't need them and that he knows how to go around them. What do you all think his,"Thank You Tour", is? Not to mention his Tweets. This man is a tank and the evil, baby killing, libertards have good justification to be scared. He's going to destroy the morons in our nation.  

Very good point LGD. I have always thought the RV would help the federal deficit, the taxes collected from the instant wealth. You also have to think about the jobs created from the people wanting to start business.

[Shedagal]

oops, you know what, I should have looked at this better.  I see the ordinary income first - I saw the cap gains and immediately reacted - sorry!!

[captl1]

Articles likethis one is why Tequila was invented!  Mas Tequila DV!

[Officiallytook]

I can poop right now I'm so excited

[fnbplanet]

I've heard it from both sides - ordinary income and personal capital gains (long AND short term, depending on how long you've owned it).  Right now, cap gains are atrocious, around 39% at the amounts that most here will be dealing with.  

My belief is that our next Prez will push the tax reduction very, very early in his agenda, so as to get a QUICK jumpstart to our languishing economy.  The faster that he can show results, the faster the tide of public opinion will turn his way.  With the populace embracing his policies even more, any and every politician with any hopes of re-election next time up will HAVE to climb aboard the band wagon.  That, in turn, would accelerate the agenda of making America GREAT again.  

I admit, I was a Ted Cruz guy, but the plan this man is putting together just fascinates me.

 

Anyway, whatever he will do about taxes will happen THIS (tax) YEAR (2017).  If this RV happens anytime soon, my bet is that whoever I get to advise me on my new wealth will tell me to exchange only what I need to right away, and to see how the chips fall after that.

[balkanbob]

I'm with you on that idea. Let the RV happen soon.