Data / Federal rules / 2026-16569
Foreign Currency Gain or Loss of Controlled Foreign Corporations
The Internal Revenue Service published this proposed rule in the Federal Register on August 14, 2026. Comments are due by November 12, 2026.
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What the agency says
This document contains proposed regulations providing rules relating to the determination and recognition of foreign currency gain or loss with respect to qualified business units ("QBUs") of controlled foreign corporations ("CFCs"). The proposed regulations provide an election under which a CFC generally would not be required to compute or recognize foreign currency gain or loss upon a remittance from a QBU, except in connection with certain inbound nonrecognition transactions.
Key facts
- Document number
- 2026-16569
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- August 14, 2026
- Comments due
- November 12, 2026
- Dates
- Written or electronic comments and requests for a public hearing must be received by November 12, 2026.
- Docket
- REG-103844-26
- Regulation ID (RIN)
- 1545-BS16
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 24
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Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in August 2026
Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.