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NEW IRS Foreign Currency Guidance


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So we wait until Trump is in before we exchange our money?

8 hours ago, fnbplanet said:

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).

 

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Great find fnbplanet thank you. And to all of you other smarties !! You make it a little easier for the rest of us Thank ya kindly !. :twothumbs:

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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. Wha

OK, everybody, take a deep breath.  I am a tax professional.  In order for Section 987 to be applicable, a taxpayer must, first and foremost, be engaged in what is termed a "Section 987 transaction,"

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 transactio

Again, seek professional advice.

 My plan is to NOT rush to the bank with all of my dinar and see what kind of special treatment or reduced exchange fees that I can get.  I will most probably wander in with a 1000 dinar note and see what they can do for me, and observe "the process".  I'll be tuning in here to see what others are experiencing.  I've waited this long, so I plan on NOT rushing in and making huge mistakes. I'll choose my advisors wisely, and research them carefully.

My GUESS is that there may be an initial low rate, like 1:1, followed a few weeks later by their higher, real intended rate.  If I'm wrong, the currency will still be good for years.  I believe the value will go UP, and the taxes on that money will come DOWN.  

Been po this long, I can wait a month and learn from everyone else's mistakes and successes!

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7 hours ago, MANNY99 said:

 

Where did it say Iraq?

One must assume when they are speaking of foreign currency that the IQD must be included as a  foreign currency as well, also I think we have seen articles of the IRS spending time advising at the CBI, just reading between the lines without blinders.

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9 hours ago, Botzwana said:

My ladies keeps putting out the crap that it will lop.  I am so sick of her.

When someone is starved for ATTENTION, they will do and say anything to get it.....even if going against the grain is the only way they can get it.....sicko's do weird things.

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1 hour ago, chinadawg said:

When someone is starved for ATTENTION, they will do and say anything to get it.....even if going against the grain is the only way they can get it.....sicko's do weird things.

LOL. Sicko. LOL again. Hear that, gals?

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42 minutes ago, 429 said:

LOL. Sicko. LOL again. Hear that, gals?

***///

Whoa, whoa, whoa... ! :o Let's be clear.... the target of ire here is against guru myladies,

NOT 'OlSarge'sGals !  Us 'Gals' are NOT gurus or the 'ladies' of some guru ! :shrug::(

 

Man, oh, man... that was close !......gotta keep yer 'Gals' separate or all hell breaks loose ! :lol::P

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We must admit, this is a GREAT window to be in. The wheels are certainly spinning 

quite nicely. Security is coming, Abadi is doing his job as PM. Trump the biz man is taking office SOON. 

Looks like things are lining up for a GREAT 17.

GO BIG, GO TRUMP, GO   RVVVVVV

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***/// We see / hear THAT, KENNYC.... considering the evil da'esh, the damned Iranians, ho'bummer,

the Chi-Coms, greedy OPEC, Chrissy LaGarde getting whacked up the side o' her head, evil maliki,

 the inter-tribal discourse, the head-butts with The Kurds, the pipeline arguments, etc, etc, etc... we're

still being assured by Abadi's ability to hold / bring it all together for the good of The Iraqi People. :twothumbs:

(and indirectly -- us Dinarians !):eyebrows:

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57 minutes ago, ChuckFinley said:

The two times I got my butt kicked in was by Jose Cuervo. So I give that man 3 shots, but not the 4th.   

GM DV. I AM A:jester:FOR TRUSTING JOSE. THREE TIMES HE'S LEFT ME FACE DOWN BEHIND THE COUCH! HE IS NOT WELCOME AT MY HOUSE!:angry::D

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I'm getting really bored having to address the annual amateur panic over IRC sections that have absolutely NOTHING to do with the taxation of the pie-in-the-sky profit hopes of the dinar INVESTORS who gather here.  The code sections in the upper 900's you stress over deal with only two types of currency transactions:

1.  Trivial, non-business gains or losses on PERSONAL transactions (typically small gains or losses incurred on currency conversions when traveling); and,

2.  Currency gains/losses incurred incident to THE ACTIVE CONDUCT OF A TRADE OR BUSINESS.

Buying dinars in the hope of gains from its appreciation against the dollar is an INVESTMENT transaction unless you are in the currency trading business, and that would require you to be doing many trades a day in multiple currencies. 

Think of your D's as shares of stock.  They will be taxed in exactly the same way.  You should know how investors in stocks are taxed when they sell their shares, and if you don't, you sure as hell should not be investing in anything!

But what do I know?  I was only a tax department managing partner in a national CPA firm with many international business clients and a tax manager in a Fortune 500 company with world wide businesses and investments (that is an either/or characterization for each individual activity or asset).  If you want all the details so you can decide whether my views are correct, feel free to hire an expert (starting at around $400,000 a year) to explain it all to you.  Shouldn't take more than a few years if you're a quick study.

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2 hours ago, Xtaxguy said:

I'm getting really bored having to address the annual amateur panic over IRC sections that have absolutely NOTHING to do with the taxation of the pie-in-the-sky profit hopes of the dinar INVESTORS who gather here.  The code sections in the upper 900's you stress over deal with only two types of currency transactions:

1.  Trivial, non-business gains or losses on PERSONAL transactions (typically small gains or losses incurred on currency conversions when traveling); and,

2.  Currency gains/losses incurred incident to THE ACTIVE CONDUCT OF A TRADE OR BUSINESS.

Buying dinars in the hope of gains from its appreciation against the dollar is an INVESTMENT transaction unless you are in the currency trading business, and that would require you to be doing many trades a day in multiple currencies. 

Think of your D's as shares of stock.  They will be taxed in exactly the same way.  You should know how investors in stocks are taxed when they sell their shares, and if you don't, you sure as hell should not be investing in anything!

But what do I know?  I was only a tax department managing partner in a national CPA firm with many international business clients and a tax manager in a Fortune 500 company with world wide businesses and investments (that is an either/or characterization for each individual activity or asset).  If you want all the details so you can decide whether my views are correct, feel free to hire an expert (starting at around $400,000 a year) to explain it all to you.  Shouldn't take more than a few years if you're a quick study.

You're so smart and yet you do something as stupid as attack 48 thousand folks for believing is something you clearly don't. The real sad part is that you will be the first to offer your services to us when this does pop.

Oh and I almost forgot. VIP eliminates all of these supposed issues. That is the tax expert everyone needs to consider.  

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26 minutes ago, Life support said:

Xtaxguy:

If your bored with the subject don't bother to comment. I'm very interested in everyones opinion,  including yours  but your bad attitude taints your comments. 

EXACTLY :bravo:

9 minutes ago, four wheel drift said:

Xtaxguy if the power went out you would freeze to death.

Good info don't be a azz

Sounds like you need to be loved. Lol

FWD

GO RV

 

He's a tax collector, even in the Bible the only person that could love them was Jesus. :eek::lmao:

relax everyone! It was a joke. 

Edited by ladyGrace'sDaddy
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Guys, listen, you're reacting just the way he wanted you to do.  All you have to do is look at his name - Xtaxguy - nuff said!!  Just kidding, Xtaxguy.  I agree with Four Wheel, you probably just need some Christmas love! 

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13 hours ago, SgtFuryUSCZ said:

***///

Whoa, whoa, whoa... ! :o Let's be clear.... the target of ire here is against guru myladies,

NOT 'OlSarge'sGals !  Us 'Gals' are NOT gurus or the 'ladies' of some guru ! :shrug::(

 

Man, oh, man... that was close !......gotta keep yer 'Gals' separate or all hell breaks loose ! :lol::P

Aren't you the Ladies of Ol Sarge?  I always thought you were proud of that.

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