Document Headings

                    Document headings vary by document type but may contain                    the following:                  
                -                       the agency or agencies that issued and signed a document                    
                -                       the number of the CFR title and the number of each part                      the document amends, proposes to amend, or is directly                      related to                    
                -                       the agency docket number / agency internal file number                    
                -                       the RIN which identifies each regulatory action listed in                      the Unified Agenda of Federal Regulatory and Deregulatory                      Actions                    

                    See the                                          Document Drafting Handbook                                        for more details.                  

###### Department of the Treasury

###### Internal Revenue Service

          - 26 CFR Part 1
          - [TD 10016]
          - RIN 1545-BO07

# AGENCY:

Internal Revenue Service (IRS), Treasury.

# ACTION:

Final rule; correction and correcting amendments.

# SUMMARY:

                        This document includes corrections to a final regulation (Treasury Decision 10016) published in the                         **Federal Register**                         on Wednesday, December 11, 2024. Treasury Decision 10016 contained final regulations relating to the determination of taxable income or loss and foreign currency gain or loss with the respect to a qualified business unit.                    

# DATES:

These corrections are effective on January 17, 2025. For dates of applicability, see § 1.987-15.

# FOR FURTHER INFORMATION CONTACT:

                        Concerning the final regulations generally, Adam G. Province at (865) 329-4546; concerning the character and source of section 987 gain or loss, Larry Pounders at (202) 317-5465; concerning consolidated groups, Jeremy Aron-Dine                               ( print page 5607)                            at (202) 317-6847 (not toll-free numbers).                    

# SUPPLEMENTARY INFORMATION:

## Background

The final regulations (TD 10016) that are the subject of this correction are under sections 861, 985 through 989, and 1502 of the Internal Revenue Code.

## Corrections to Publication

                    Accordingly, FR Doc. 2024-28372 (TD 10016) appearing on page 100138 in the                     **Federal Register**                     on Wednesday, December 11, 2024, is corrected as follows:                

1. On page 100155, in the third column, under the caption “A. Loss Suspension Rule 1. In General”, the second line of the third full paragraph is corrected to read “proposed § 1.987-11(c)”.

# List of Subjects in 26 CFR Part 1

      - Income taxes
      - Reporting and recordkeeping requirements

## Correction to the Regulations

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

# PART 1—INCOME TAXES

**Paragraph 1.**                         The authority citation for part 1 continues to read in part as follows:                    

Authority:26 U.S.C. 7805 * * *

**Par. 2.**                         Section 1.987-1 is amended by revising the first sentence of paragraph (b)(3)(ii)(A) to read as follows:                    

§ 1.987-1

* * * * *

(b) * * *

(3) * * *

(ii) * * *

(A) * * * Solely for purposes of section 987, an owner may elect to treat all section 987 QBUs with the same functional currency as a single section 987 QBU except to the extent provided in paragraph (b)(3)(ii)(B) of this section. * * *

* * * * *

**Par. 3.**                         Section 1.987-2 is amended by revising the second sentence of paragraph (c)(10)(xviii)(B)(                        *2*) to read as follows:                    

§ 1.987-2 

* * * * *

(c) * * *

(10) * * *

(xviii) * * *

(B) * * *

                            (                            *2*) * * * Under § 1.987-5(c)(4) and § 1.987-8(e), a termination of a section 987 QBU is treated as a remittance of all the gross assets of the section 987 QBU to the owner on the date of the termination. * * *                        

* * * * *

§ 1.1502-13 

**Par. 4.**                         Section 1.1502-13 is amended by redesignating the second occurrence of paragraph (j)(10)(vi) as (j)(10)(vii).                    

Regina L. Johnson,

Federal Register Liaison, Publications and Regulations Section, Associate Chief Counsel (Procedure and Administration).

[FR Doc. 2025-01248 Filed 1-16-25; 8:45 am]

BILLING CODE 4830-01-P