Treasury Regulations · 26 CFR
§ 1.987-6T. Character and source of section 987 gain or loss (temporary).
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 § 1.987-6T
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- December 8, 2016 by T.D. 9795
- Issued under
- 26 U.S.C. § 987
- Length
- 203 words · about 1 min to read
- Cross-references
- cites 1 Code section and 4 regulations; cited by 1
¶(4) Source of section 987 gain or loss with respect to a dollar QBU. The source of section 987 gain or loss with respect to a dollar QBU (as defined in § 1.987-1T(b)(6)(i)) for which the CFC owner has elected under § 1.987-1T(b)(6)(iii) to apply section 987 is determined by reference to the residence of the CFC owner. This paragraph (b)(4) applies to any CFC that has made the election under § 1.987-1T(b)(6)(iii), including a CFC described in § 1.987-1(b)(1)(ii).
¶(d) Effective/applicability date. This section applies to taxable years beginning on or after one year after the first day of the first taxable year following December 7, 2016. Notwithstanding the preceding sentence, if a taxpayer makes an election under § 1.987-11(b), then this section applies to taxable years to which §§ 1.987-1 through 1.987-10 apply as a result of such election.
¶(e) Expiration date. The applicability of this section expires on December 6, 2019.
[T.D. 9795, 81 FR 88874, Dec. 8, 2016]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 1.987-6 Character and source of section 987 gain or loss.
- § 1.987-1T Scope, definitions, and special rules (temporary).
- § 1.987-1 Scope, definitions, and special rules.
- § 1.987-11 Suspended section 987 loss relating to certain elections; loss-to-the-extent-of-gain rule.
Cited by 1 other regulation
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. 9795 (81 FR 88874)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Foreign Currency Transactions
Nearby sections
- § 1.987-3T Determination of section 987 taxable income or loss of an owner of a section 987 QBU (temporary).
- § 1.987-4 Determination of net unrecognized section 987 gain or loss of a section 987 QBU.
- § 1.987-5 Recognition of section 987 gain or loss.
- § 1.987-6 Character and source of section 987 gain or loss.
- § 1.987-6T Character and source of section 987 gain or loss (temporary).
- § 1.987-7 Application of the section 987 regulations to partnerships and S corporations.
- § 1.987-8 Termination of a section 987 QBU.
- § 1.987-8T Termination of a section 987 QBU (temporary).
- § 1.987-9 Recordkeeping requirements.