Treasury Regulations · 26 CFR
§ 1.987-8T. Termination of a section 987 QBU (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 § 1.987-8T
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
- 188 words · about 1 min to read
- Cross-references
- cites 1 Code section and 2 regulations; cited by 3
¶(d) Annual deemed termination election. A taxpayer, including a taxpayer described in § 1.987-1(b)(1)(ii) to which §§ 1.987-1 through 1.987-11 generally do not apply, may elect under this paragraph (d) to deem all of the section 987 QBUs of which it is an owner to terminate on the last day of each taxable year for which the election is in effect. See § 1.987-8(e) regarding the effect of such a deemed termination. The owner of a section 987 QBU that is deemed to terminate under this paragraph is treated as having transferred all of the assets and liabilities attributable to such section 987 QBU to a new section 987 QBU on the first day of the following taxable year.
¶(g) Effective/applicability date. This section applies to taxable years beginning on or after December 7, 2016.
¶(h) Expiration date. The applicability of this section expires on December 6, 2019.
[T.D. 9795, 81 FR 88875, Dec. 8, 2016]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
Cited by 3 other regulations
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 88875)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Foreign Currency Transactions
Nearby sections
- § 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.
- § 1.987-10 Transition rules.
- § 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.