10
Nov
Treasury and the IRS on November 9 released proposed regulations relating to the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit (QBU). The proposed regulations include an election to treat all items of a QBU as marked items (subject to a loss suspension rule), an election to recognize all foreign currency gain or loss with respect to a QBU on an annual basis, and a new transition rule. The proposed...