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[Federal Register Volume 90, Number 11 (Friday, January 17, 2025)]
[Rules and Regulations]
[Pages 5606-5607]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-01248]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 10016]
RIN 1545-BO07

Taxable Income or Loss and Currency Gain or Loss With Respect to 
a Qualified Business Unit; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final rule; correction and correcting amendments.

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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 Sec.  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

[[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 Sec.  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

0
Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

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

0
Par. 2. Section 1.987-1 is amended by revising the first sentence of 
paragraph (b)(3)(ii)(A) to read as follows:

Sec.  1.987-1   Scope, definitions, and special rules.

* * * * *
    (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. * * *
* * * * *

0
Par. 3. Section 1.987-2 is amended by revising the second sentence of 
paragraph (c)(10)(xviii)(B)(2) to read as follows:

Sec.  1.987-2  Attribution of items to eligible QBUs; definition of a 
transfer and related rules.

* * * * *
    (c) * * *
    (10) * * *
    (xviii) * * *
    (B) * * *
    (2) * * * Under Sec.  1.987-5(c)(4) and Sec.  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. * * *
* * * * *

Sec.  1.1502-13  [Amended]

0
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
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