Overview of IRC Section 988 Nonfunctional Currency Transactions

LB&I International Practice Service

Concept Unit

IPS Level Number Title UIL Code Number

Shelf N/A Crossover IPN – –

Volume 18 Foreign Currency Level 1 UIL 9470

Part 18.2 Transactions in a foreign currency - §988 Level 2 UIL 9470.02

Chapter 18.2.1 Computation of exchange gain or loss - general Level 3 UIL 9470.02-01

Sub-Chapter N/A N/A

– –

Unit Name Overview of IRC Section 988 Nonfunctional Currency Transactions

Document Control Number (DCN) FCU/CU/C_18.2.1_03(2016)

Date of Last Update 06/01/2016

Note: This document is not an official pronouncement of law, and cannot be used, cited or relied upon as such. Further, this document may not contain a

comprehensive discussion of all pertinent issues or law or the IRS's interpretation of current law.

DRAFT

Table of Contents

(View this PowerPoint in “Presentation View” to click on the links below)

General Overview

Diagram of Concept

Facts of Concept

Detailed Explanation of the Concept

Examples of the Concept

Training and Additional Resources

Glossary of Terms and Acronyms

Index of Related Issues

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General Overview

Overview of IRC Section 988 Nonfunctional Currency Transactions

This Concept Unit covers the following:

1) “Functional currency” (FC) and its application,

2) Definition of Section 988 transactions,

3) Computation of foreign currency gain/loss under IRC 988 on receivables/payables denominated in a nonfunctional currency

(including US GAAP ASC 830 (formerly FAS 52) differences), and

4) Computation of foreign exchange gain/loss under IRC 988 on debt instruments denominated in a nonfunctional currency.

Except as provided in the code and regulations, a taxpayer’s functional currency is the US dollar (USD). A taxpayer or a Qualified

Business Unit (QBU) - any separate and clearly identified unit of a taxpayer that maintains separate books and records) may, under

certain circumstances, have a non-USD functional currency (see IRC 985(b); Treas. Reg. 1.985-1(b) and (c)). Note that US

Corporations must have the USD as their functional currency, although t heir foreign branches may have non-USD functional

currencies (a QBU can have a functional currency that is different from its owner). The functional currency is relevant for taxpayers

that have transactions in multiple currencies. Transactions are accounted for in the taxpayer's functional currency. Certain

nonfunctional currency transactions, called “Section 988 transactions” generally give rise to functional currency gain or loss.

Transactions that require the use of a currency other then US dollar have dramatically increased as more taxpayers do business

globally. Generally, when US resident taxpayers invest and do business transactions in non US currency, all federal tax

determinations must be made in USD. Section 988 transactions include debt instruments, payables, receivables, forward contracts,

futures contracts, options or similar instruments denominated in any nonfunctional currency. Also when a taxpayer owns or has a

position in a nonfunctional currency asset or liability that generates a Section 988 transaction, the US taxpayer must calculate foreign

currency gain or loss. (See the above paragraph f or a description of the term “functional currency.”) Sections 985 to 989 provide rules

for making translations and measuring foreign currency gain or losses.

IRC 988 and its regulations generally provide that foreign currency gain or loss with respect to a transaction is (1) recognized at the

time of the sale or disposition of nonfunctional currency denominated property, (2) characterized as ordinary gain or loss, and (3)

sourced based upon the residence of the holder.

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General Overview (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

IRC Sections 985 to 989 provide rules for translating tax items into a taxpayer’s functional currency and measuring foreign currency

gain and losses. In general:

 Section 985 - Defines functional currency including hyperinflationary currency

 Section 986 - Addresses the translation into USD of foreign taxes and foreign corporation’s earning and profits

 Section 987 - Addresses branch transactions when the QBU has a different functional currency than the taxpayer

 Section 988 - Describes treatment of certain foreign currency transactions

 Section 989 – Defines a qualified business unit (QBU) and appropriate exchange rate

This IPS Unit will focus on the basic functional currency concepts and the treatment of certain nonfunctional currency transactions

under IRC 988. For each example listed in the Examples section of this unit, the first line of the diagram description will reflect the

entity name and the second line will reflect the functional currency (FC) of the entity:

Other IPS units for IRC 989, IRC 987 and other foreign currency issues are in the IPS library.

HoldCo

Luxembourg

FC = USD

Entity name

Functional Currency

Country

of Residence

Note:

The Internal

Revenue Code refers to foreign currency

gains and losses while the Treasury

Regulations

use the term

exchange gain or

loss.

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Diagram of Concept

Overview of IRC Section 988 Nonfunctional Currency Transactions

Diagram of Concept

USC

FC=USD

Peso

Receivables/Payables

Pay

Invoice

JPY

Canadian Dollar

Debt

Repayment

Bank

FC=CAD

CFC

FC=EUR

Euro

Receivables/Payables

DE

FC=MXP

 DE is a Section 987 QBU

 Assume no transactions between

D

E

and USC

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Facts of Concept

Overview of IRC Section 988 Nonfunctional Currency Transactions

Facts of Concept

It is very common that US companies will be transacting in currencies other then the US dollar. Examiners need to understand:

 the cash flow of these transactions,

 how they are recorded for financial accounting and t ax purposes, and

 any foreign currency gain or loss that should be reported, as well as the source (US or foreign) and character (ordinary or capital) of

the transaction.

Nonfunctional currency transaction am ounts have to be translated into functional currency. An example of this type of transaction is

paying an invoice in a nonfunctional currency. For example, in the Diagram of Concept (prior slide), USC’s invoice is payable in

Japanese Yen.

When the US taxpayer owns foreign currency or has a position in a non-US currency asset or liability, examiners need to be able to

measure, translate and establish when foreign currency gains and losses should be determined. For example, in the Diagram of

Concept (prior slide), USC has both Euro denominated receivables/payables and a Canadian Dollar debt.

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Detailed Explanation of the Concept

Overview of IRC Section 988 Nonfunctional Currency Transactions

What is a Section 988 transaction? Generally, it is a transaction where the amount that the taxpayer is entitled to receive or required

to pay is determined in a currency other than the functional currency of the taxpayer or is determined in reference to the value of one

or more nonfunctional currencies. These transactions are described in greater detail below.

Analysis Resources

 (i) the acquisition of a debt instrument or becoming the obligor under a debt instrument;

 (ii) accruing (or otherwise taking i nto account) any items of expense or gross income or

receipts which is to be paid or received after the date on which so accrued or taken into

account (i.e., payable and receivables, provided that for tax purposes, the accrual and

payment dated are distinct); and

Subject to certain statutory exceptions, transactions include:

 (iii) entering into or acquiring any forward contract, futures contract, option, or similar

financial instrument.

 IRC 988(c)(1)(B) and Treas. Reg.

1.988-1(a)(2)

The disposition of any nonfunctional currency is also treated as a Section 988 transaction and

any gain or loss arising from such transaction is treated as a foreign currency gain or loss.

 IRC 988(c)(1)(C) and Treas. Reg.

1.988-2(a)(1)(i)

Section 988 transactions includes certain financial derivatives. Financial derivatives such as

forwards, futures, options contracts, etc. are used by taxpayers to reduce exposure to

underlying currency and asset transfer risks. The Internal Revenue Code establishes different

tax rules governing how and when foreign currency gains and losses are taxed for different

financial instruments.

CONSULTATION: When a transaction includes complex financial derivatives, the

Examiner should consult with a Financial Products Examiner.

 IRC 988(c)(1)(D) – (E) and 988(d)

 See IPS Concept Unit Overview of

Foreign Currency Hedging

Transactions DCN

FCU/CU/C_18.2.3_14

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Detailed Explanation of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

How are Section 988 transactions treated for tax purposes? While the transactions are generally treated as ordinary income, certain

exceptions, rules and elections exist that treat these transactions as capital in nature. Likewise, these transactions are generally

sourced based on the residence of the taxpayer; however there are exceptions to this rule.

Analysis Resources

Foreign currency gain or loss attributable to a section 988 transaction is computed separately

and generally treated as ordinary.

 IRC 988(a)(1)(A) and Treas. Reg.

1.988-3(a)

However, a taxpayer or QBU may elect to treat gain or loss on certain forwards, futures, and

options as capital gain or loss.

 IRC 988(a)(1)(B) and Treas. Reg.

1.988-3(b)

 See IPS Concept Unit on Character

of Exchange Gain or Loss on

Currency Transactions, DCN

FCU/CU/C-18.2.1_04 for further

discussion

Generally, the source of foreign currency gain or loss is determined by reference to the

residence of the taxpayer or QBU.

 IRC 988(a)(3) and Treas. Reg. 1.988-

4

 See IPS Concept Unit on Sourcing of

Exchange Gains or Losses, DCN

FCU/CU/C-18.2.1_17 for further

discussion

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Detailed Explanation of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

What about other transactions denominated in nonfunctional currency? IRC Section 988 clearly defines transactions covered under

this subchapter. Therefore, while other transactions may have foreign currency components as discussed below, the character and

sourcing of these transactions are not governed by IRC Section 988 and are therefore both sourced and characterized by separate

Code sections.

Analysis Resources

Transactions not defined in IRC 988 are not treated as Section 988 transactions. Fluctuations

in exchange rates may nonetheless generate foreign currency gains or losses realized by a

taxpayer on other transactions.

 See IPS Concept Unit on Overview

of the Impact of Foreign Currency

Exchange Rate Fluctuations” DCN

FCU/CU/C-18.2.1_16

For example, purchasing stock in a nonfunctional currency is not a Section 988 transaction

because stock is not a Section 988 asset. A taxpayer generally determines its basis in the

stock and amount realized upon disposition of the stock using a spot rate.

However, the initial acquisition of nonfunctional currency and subsequent disposition of

nonfunctional currency to acquire the stock would be a Section 988 transaction if the

acquisition and disposition of the currency occurred on separate dates.

 IRC 1221

 IRC 988(c)(1)(C)

Example: Assume Dorfman Corp, a taxpayer with USD as its functional currency, purchased

a share of stock for LC100 when LC100=USD100. Assume Dorfman Corp holds the stock as

capital asset. Further assume that Dorfman Corp sold the stock for LC100 when

LC100=USD150.

Dorfman Corp had a USD50 gain attributable to the stock. However, because holding stock

is not a defined Section 988 transaction, the USD50 gain would not be foreign currency gain.

The gain on the stock is a capital gain.

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DRAFT

DE

(LC1)

Examples of the Concept

Overview of IRC Section 988 Nonfunctional Currency Transactions

Examples

USC

FC=USD

DE

FC=LC1

CFC

FC=LC2

Illustration #1 - Understand the term functional currency (FC), its application, and

IRC 988 application

Facts:

 USC owns two foreign entities; DE and CFC.

 DE manufactures in Foreign Country 1 and maintains its own separate books

and

records

using currency LC1.

DE

is

a QBU.

 CFC

sells products

in Foreign Country 2 and also has its

own separate books

and records

using

currency

LC2.

CFC is a QBU.

Results:

 USC

FC

is

the USD. See Treas. Reg. 1.985-1(b).

 DE is a QBU with FC being

LC1.

See Treas.

Regs. 1.985-1(c) and 1.989(a)-

1(b)(1); IRC

987.

 CFC is a QBU

with FC being

LC2.

See Treas.

Reg.

1.985-1(c)

and 1.989(a)-

1(b)(2) (providing that

a corporation

is

a per se QBU).

 DE

and CFC’s

profit and loss

at

the end of the year

is

translated

to dollars

using the average exchange rate for the year

after

making

US GAAP

adjustments. The DE

profit or

loss

(P/L)

flows

into USC’s

Form

1120;

however

CFC’s P/L is deferred and reported as

information on Form 5471.

The CFC’s

gains on an Section 988 transaction

(debt/receivable/payable/options etc.)

is

foreign personal holding c

ompany

income (FPHCI),

unless an exception (e.g.,

business needs) applies.

See IRC

954(c)(1)(D)

and Treas.

Reg.

1.954-

2(g)(2)(ii).

NOTE: For definition of QBU, see Overview of Qualified Business Units (QBU),

DCN FCU/CU/C_18.3.1_02.

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Examples of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

Examples

USC

FC=USD

CFC

FC=LC

USD

Payment

Illustration #2 - Loan denominated in a nonfunctional currency including US

GAAP (ASC 830-20-35, formerly FAS 52) differences

Facts:

 USC’s functional currency is the US Dollar (USD) and CFC’s functional

currency is LC. USC advances USD100 to CFC, on 12/01/20X1 when the

exchange is USD1:LC1. Rate changes to USD1:LC1.25 on 12/31/20X1 and

to USD1:LC1.5 on 03/31/20X2 when the loan is paid.

 CFC’s loan payable is a Section 988 transaction.

Results – Accounting:

 Re-measurement is required by US GAAP (ASC 830) for financial

accounting purposes. The CFC will record an unrealized financial loss in

the P&L at 12/31/X1 and then recognize a realized financial loss on 03/31/X2

as noted below:

Unrealized Loss @ 12/31/20X1 = $100 x (1.25-1.00) = $25 loss

Realized Loss @ 03/31/20X2 = $100 x (1.50 – 1.00) = $50 total loss

Less unrealized loss previously recognized: ($25)

Additional Loss booked on 03/31/20X2: $25 loss in 20X2

!

CAUTION: Special Treatment of Intercompany transactions (within

consolidated, combined groups or equity accounting) treated as part of

the net investment , see ASC 830-20-35-5:

 If an intercompany foreign currency transaction is of a “long-term

investment” nature, foreign currency transaction G/L are reported in

other comprehensive income (OCI) rather than through the P&L.

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Examples of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

Examples

USC

FC=USD

CFC

FC=LC

USD

Payment

Illustration #2 (cont’d)

Results – Tax:



Realized gains/losses (G/L) are recognized in the year that the

payment is made. See Treas. Reg. 1.988-2(b)(6). CFC recognizes

a loss in earnings and profits (E&P) in 03/31/X2 as noted below:

Realized Loss @ 03/31/20X2 = $100 x (1.50 – 1.00) = $50 total loss

Assuming debt treatment for US GAAP

Financial

Accounting

P&L

Tax E&P

Sch M-3

E&P Adj

12/31/20X1 (25) 0 25

12/31/20X2 (25) (50) (25)

Assuming long-term investment for US GAAP

Financial

Accounting

P&L

Tax E&P

Sch M-3

E&P Adj

12/31/20X1 - 0 -

12/31/20X2 - (50) (50)

 Unrealized gains / losses (G/L) recorded for financial accounting may

be incorrectly reported for tax purposes or not reported when paid for

tax purposes in the following year.

 Schedule H of Form 5471 for the CFC should be analyzed to

determine the taxpayer’s treatment of the transaction and to

ascertain whether additional E&P adjustments are required.

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Examples of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

Examples

USC

FC=USD

Loan

Bank

FC=LC1

Machine

Invoice

LC1

Pays Invoice

Illustration #3 – IRC 988 computation of realized foreign currency gain

or loss on a nonfunctional currency payable

Facts:

 USC, an accrual basis taxpayer with USD FC, borrowed from a bank

in 20X2.

 The loan from bank is a 5 year note with a face amount of LC1 100

with interest accruing q uarterly.

 USC separately orders a machine for LC1 100. The machine invoice

term is 60 day upon delivery. The LC1 is worth $110 US dollars when

the machine is received (and the expense accrues) and $105 US

dollars when the invoice is paid.

Results:

 Purchase of machine is not an Section 988 transaction. USC records

an asset for $110 and an accounts payable of $110 when machine is

received. See generally IRC 988.

 Disposition or payment of accounts payable would be an Section 988

transaction and give rise to foreign currency gain or loss – an ordinary

gain of $5 US dollars under Treas. Reg. 1.988-3(a) and US source

under residence rule of sourcing.

 The five year note denominated in terms of a nonfunctional currency

is an Section 988 transaction and gain/loss recognized when paid

(see Illustration #4).

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Examples of the Concept (cont’d)

Overview of IRC Section 988 Nonfunctional Currency Transactions

Examples

USC

FC=USD

Loan

Bank

FC=LC1

Machine

Invoice

LC1

Pays Invoice

Illustration #4 – IRC 988 nonfunctional currency debt instrument and

computation of realized and unrealized foreign currency gains or losses

Facts:

 USC, an accrual basis taxpayer with USD as its functional currency,

borrowed from bank in 20X2 to purchase a machine.

 Loan from bank is a five year note with a face amount of LC1 100

with quarterly payment of interest only.

– Note when acquired: USD 101 = LC1 100

– Note at the end of 20X2 BS measurement date: USD 94 = LC1

100

– Note paid in full when USD 90 = LC1 100

Results:

 Five year note denominated in terms of a non-FC is a Section 988

transaction and foreign currency gain/loss is recognized for tax

purposes when paid.

 Unrealized G/L not recognized while note is outstanding.

For financial purposes, an unrealized foreign currency gain of USD7 will

be reported at the end of 20X2.

 FC tax gain of USD11 is recognized when 5 year note paid.

 Accrued interest expense is also an Section 988 item in accordance

with Treas. Reg. 1.988-1(a)(1)(ii) and Treas. Reg. 1.988-1(a)(2)(ii),

and gain or loss is recognized when accrued payments are made, as

determined under Treas. Reg. 1.988-2(b)(3) & (4).

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Training and Additional Resources

Chapter 18.2.1 Computation of Exchange Gain or Loss - General

Type of Resource Description(s) and/or Instructions

for Accessing

References

Saba Meeting sessions  IBC ONLY – Foreign Currency & Int’l

Matrix (Saba – Public Recordings –

Event ID JVQ439517)

 IBC Common Errors in translating

Foreign Currency 44 (Saba – Public

Recordings – Event ID PHG711242)

 The Building Blocks of Financial

Products (Saba – Public Recordings

– Search on “Building Blocks of

Financial Products)

 2011 Saba – Foreign Currency & Intl

Matrix

 2012 Saba –Common Errors in

translating Foreign Currency 44

 2013 Saba – The Building Blocks of

Financial Products

Other Training Materials (Saba Meeting sessions) IE Phase III Hybrid sessions:

 IRC 985 and 989 :Foreign Currency

Terms and Definitions

 Section 986 Translation Rules

 Sec 987 – Branch rules and CTB

rules

 Foreign Currency Section 988

Transactions

 2015 Saba – FC 1 Sec 985

(HQL168303)

 2015 Saba – FC 2 986 Transition

Rules (FRS408475)

 2015 Saba – FC 3 987 Branch Rules

& CTB (LVP748808)

 2015 Saba – FC 4 Sec 988

Transactions (FTS047865)

 Foreign Currency Hedging

 Financial Products Basics – Four

Major Categories

 2015 Saba – FC 5 Foreign Currency

Hedging (HTS256974)

 2015 Saba – Financial Products

Basics (JNN441732)

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Training and Additional Resources (cont’d)

Chapter 18.2.1 Computation of Exchange Gain or Loss - General

Type of Resource Description(s) and/or Instructions

for Accessing

References

Other Training Materials  IE Phase I, Module E – Lesson 1

Foreign Currency

http://lmsb.irs.gov/hq/mf/training/inter

national/phase1/phase_1.asp, Select

Module E

 IE Phase III, Module D –Interaction of

International and Financial Products

Issues

http://lmsb.irs.gov/hq/mf/training/inter

national/phase3/phase_3.asp, Select

Module 5.D., second lesson

Other Training Materials  FP Phase I, Lesson 9 Foreign

Currency

 FP Phase I, Download Financial

Products Phase One Participant

Guide, then proceed to Lesson 9,

page 9-1.

 FP Phase III, Lesson 4 Foreign

Currency

 FP Phase III, Download Financial

Products Phase Three Participant

Guide, then proceed to Lesson 4,

page 110.

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Training and Additional Resources (cont’d)

Chapter 18.2.1 Computation of Exchange Gain or Loss - General

Type of Resource Description(s) and/or Instructions

for Accessing

References

Bittker & Lokken – Federal Taxation of Income,

Estates and Gifts

 Bittker and Lokken Para 74.2

Functional Currency

(Westlaw subscription)

 FIXIEG Para 74.2

BNA Tax Management Portfolio  BNA Portfolio 921-2nd Tax Aspects of

Foreign Currency

(Westlaw subscription)

 BNA 921-2nd – TMFEDPORT No

921 s

Keyes: Federal Taxation of Financial Instruments

and Transactions

 Keyes Chapter 15. Foreign Currency

Denominated Instruments

Mertens Law of Federal Income Taxation  Mertens Chapter 45C. SOURCING

OF INCOME AND EXPENSE, III

45C:63 Functional currency —

Qualified business unit

(Westlaw subscription)

Accounting Standards Codification (Financial

Accounting Standards)

 ASC830 (FAS52) Foreign Currency

Matters

 Available at https://asc.fasb.org.

Register for free “basic view” service.

 Westlaw subscription: IRS LB&I Tab.

Under Financial Accounting, choose

RIA FASB Codification Complete

Analysis, Table of Contents. ASC

830 is under the Broad Transactions

in the Codification section.

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Glossary of Terms and Acronyms

Term/Acronym Definition

ASC Accounting Standard Codification

BS Balance Sheet

CFC Controlled Foreign Corporation

DE Disregarded Entity

E&P Earnings and Profits

FAS Financial Accounting Standards

FC Functional currency

FPHC Foreign Personal Holding Company

FX Foreign currency or foreign exchange

G/L Gain or Loss (or Gains/Losses)

GL General Ledger

OCI Other Comprehensive Income

P&L Profit and Loss Statement (Income Statement)

P/L Profit or Loss

QBU Qualified Business Unit

US GAAP US Generally Accepted Accounting Principles

USD US Dollar

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Glossary of Terms and Acronyms (cont’d)

Term/Acronym Definition

Forward Contract A customized contract between two parties to buy or sell an asset at a specified price on a future date.

Functional Currency The currency of the primary economic environment in which the entity operates.

Futures Contract A contract between two parties where both parties agree to buy and sell a particular asset of specific quantity

and at a predetermined price, at a specified date in the future.

Nonfunctional

Currency

A currency utilized by an entity for a transaction that is not the functional currency of the entity.

Option Contract A contract that allows the holder to buy or sell an underlying security at a specified price.

Section 988

Transaction

Transactions as defined in IRC 988(c)(1)(B)

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Index of Related Issues

Issue Associated UIL(s) References

Overview of Foreign

Currency Hedging

Transactions

 9470.02  FCU/CU/C_18.2.3_14

Overview of the Impact of

Foreign Currency Exchange

Rate Fluctuations

 9470.02  FCU/CU/C-18.2.1_16

Disposition of Nonfunctional

Currency

 9470.02  FCU/9470.02_01_04

IRC 988 currency gain or loss

determination

 9470.02  FCU/PUO/C_18.2.1_09

Character of Exchange Gain

or Loss on Currency

Transactions

 9470.02  FCU/CU/C-18.2.1_04

Sourcing of Exchange Gains

or Losses

 9470.02  FCU/CU/C-18.2.1_17

Exchange Gain/Loss on Debt

Instruments

 9470.02  FCU/CU/C_18.2.1_09

Integration of Executory

Contract and the Currency

Hedge

 9470.02  FCU/9470.02_05

Legging into Integrated

Treatment

 9470.02  FCU/9470.02_07

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Index of Related Issues (cont’d)

Issue Associated UIL(s) References

Disposition of a Portion of an

Integrated Hedge

 9470.02  FCU/9470.02_03

How to Assess Penalties for

Failure to file Form 8886

Disclosing Section 988

Losses

 9470.02  FCU/9470.02_02

Functional Currency of a

Qualified Business Unit

(QBU)

 9470.03 FC U/PUO/C_18.3.3_08

Overview of Qualified

Business Units (QBUs)

 9470.03  FCU/CU/C_18.3.1_02

Computing Foreign Base

Company Income

 9412.05  DPL/9412.05_05

Subpart F Overview  9412  DPL/CU/V_2_01

Calculation of IRC §956

Amount

 9414.01  Under Development

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