Treasury Regulations · 26 CFR
§ 1.987-15. Applicability date.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 987
Cite as 26 CFR § 1.987-15
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- December 11, 2024 by T.D. 10016
- Issued under
- 26 U.S.C. § 987
- Length
- 843 words · about 4 min to read
- Defines
- 3 terms
- Cross-references
- cites 1 Code section and 3 regulations; cited by 10
¶(2) Applicability date for a terminating QBU. The section 987 regulations apply to the owner of a terminating QBU immediately before the section 987 QBU terminates, but only with respect to the section 987 QBU, any successor deferral QBUs or successor suspended loss QBUs (in their capacity as such), and any net unrecognized section 987 gain or loss, deferred section 987 gain or loss, or suspended section 987 loss with respect thereto. See § 1.987-1(h) for the definition of a terminating QBU.
¶(b) Application of the section 987 regulations to taxable years beginning on or before December 31, 2024, and ending after November 9, 2023. A taxpayer (including a taxpayer that has applied the 2016 and 2019 section 987 regulations to a prior taxable year under paragraph (c) of this section) may choose to apply the section 987 regulations to a taxable year beginning on or before December 31, 2024, and ending after November 9, 2023, provided the taxpayer and each member of its consolidated group and section 987 electing group:
¶(1) In general. A taxpayer may choose to apply the 2016 and 2019 section 987 regulations to a taxable year beginning after December 7, 2016, and beginning on or before December 31, 2024, provided the taxpayer and each member of its consolidated group and section 987 electing group:
¶(ii) Consistently apply the 2016 and 2019 section 987 regulations in their entirety to all section 987 QBUs (within the meaning of prior § 1.987-1(b)(2)) directly or indirectly owned (within the meaning of prior § 1.987-1(b)(4)) by the taxpayer and each member of its consolidated group and section 987 electing group on the transition date for that taxable year and all subsequent taxable years before the taxable year in which the taxpayer and each member of its consolidated group and section 987 electing group apply the section 987 regulations pursuant to paragraph (a) or (b) of this section; and
¶(iii) Either—
¶(B) First apply the 2016 and 2019 section 987 regulations on their returns filed on or after November 9, 2023 and apply § 1.987-10 in lieu of prior § 1.987-10.
¶(2) Application to section 987 QBUs not owned on the transition date. For any taxable year in which a taxpayer applies the 2016 and 2019 section 987 regulations pursuant to paragraph (c)(1) of this section, the taxpayer may choose to apply the 2016 and 2019 section 987 regulations to any section 987 QBU (within the meaning of prior § 1.987-1(b)(2)) that the taxpayer did not directly or indirectly own (within the meaning of prior § 1.987-1(b)(4)) on the transition date, provided the taxpayer applies the 2016 and 2019 section 987 regulations consistently to that QBU for that taxable year and all subsequent taxable years before the taxable year in which the taxpayer applies the section 987 regulations pursuant to paragraph (a) or (b) of this section and the taxpayer either—
¶(ii) First applies the 2016 and 2019 section 987 regulations to the section 987 QBU on its return filed on or after November 9, 2023, and applies § 1.987-10 in lieu of prior § 1.987-10.
¶(3) Modifications of defined terms for purposes of this paragraph (c). Solely for purposes of this paragraph (c)—
¶(i) Application of § 1.987-10 in lieu of prior § 1.987-10. For any taxpayer to which paragraph (c)(1)(iii)(B) or (c)(2)(ii) of this section applies, the term 2016 and 2019 section 987 regulations includes § 1.987-10 and not prior § 1.987-10.
¶(d) Prior § 1.987-12. For the applicability dates of prior § 1.987-12, see prior § 1.987-12(j). Prior § 1.987-12 applies through the end of the taxable year immediately preceding the first taxable year in which a taxpayer applies § 1.987-12 pursuant to paragraph (a) or (b) of this section.
[T.D. 10016, 89 FR 100165, Dec. 11, 2024]
Terms defined here
Where the text says “the term … means”. Select a term to jump to its definition.
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 1.987-1 Scope, definitions, and special rules.
- § 1.987-10 Transition rules.
- § 1.987-12 Deferral of section 987 gain or loss.
Cited by 10 other regulations
- § 1.861-9 Allocation and apportionment of interest expense and rules for asset-based apportionment.
- § 1.985-5 Adjustments required upon change in functional currency.
- § 1.987-0 Table of contents.
- § 1.987-1 Scope, definitions, and special rules.
- § 1.987-7 Application of the section 987 regulations to partnerships and S corporations.
- § 1.987-10 Transition rules.
- § 1.988-1 Certain definitions and special rules.
- § 1.988-4 Source of gain or loss realized on a section 988 transaction.
- § 1.989(a)-1 Definition of a qualified business unit.
- § 1.1502-13 Intercompany transactions.
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 10016 (89 FR 100165)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Foreign Currency Transactions
Nearby sections
- § 1.987-11 Suspended section 987 loss relating to certain elections; loss-to-the-extent-of-gain rule.
- § 1.987-12 Deferral of section 987 gain or loss.
- § 1.987-13 Suspended section 987 loss upon terminations.
- § 1.987-14 Section 987 hedging transactions.
- § 1.987-15 Applicability date.
- § 1.988-0 Taxation of gain or loss from a section 988 transaction; Table of Contents.
- § 1.988-1 Certain definitions and special rules.
- § 1.988-1T Certain definitions and special rules (temporary).
- § 1.988-2 Recognition and computation of exchange gain or loss.