News & Analysis as of

Overview of the Taxation of Foreign Currency

In this Newsletter: - Determination of the Functional Currency and Definition of a “QBU” - Section 988 — Non Functional Currency Transactions - Section 986 — Translation Rules for Earnings and Profits and...more

Moving from the Academic to the Legislative: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives...

BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more

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