Английская Википедия:988 transaction
Шаблон:Short description Шаблон:UStaxation A 988 transaction is a transaction described in section 988(c)(1) of the Internal Revenue Code[1] in the United States of America. This transaction occurs when a taxpayer enters into or acquires any debt instrument, forward contract, futures contract, option, or similar financial instrument held in a non-functional currency.[1] The rules for 988 transactions do not apply to any regulated futures contract or non-equity options which would be marked to market under 26 USCA § 1256[2] (1256 contract) if held on the last day of the taxable year.[1]
History
The provisions covering 988 transactions were enacted as part of the Tax Reform Act of 1986.[3][4]
Application
The foreign currency gain or loss on a 988 transaction is treated as ordinary income or loss unless an election is made to treat it as a capital gain or loss.[1]
See also
References
- ↑ 1,0 1,1 1,2 1,3 26 USCA section 988
- ↑ 26 USCA § 1256
- ↑ NY CPA Journal
- ↑ See section 1261(a) of the Tax Reform Act of 1986, Pub. L. No. 99-514 (Oct. 22, 1986).
External links
