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This document contains proposed regulations that would update regulations regarding whether persons are treated as related persons who are subject to certain special rules pertaining to transactions with partnerships. The regulations affect partnerships that enter into transactions with related persons that result in gain or loss on a sale or exchange of property or result in a difference in the time at which income and deductions are recognized because of the persons’ different methods of accounting.
Taxpayers are required to recognize taxable income or loss and foreign currency gain or loss with respect to a qualified business unit that has a functional currency other than the dollar. The proposed regulations would provide an election to treat all items of a qualified business unit as marked items (subject to a loss suspension rule), an election to recognize all foreign currency gain or loss with respect to a qualified business unit on an annual basis, a new transition rule, and certain other rules. REG-132422-17. Published on November 14, 2023.
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