Skip to content

General education, not advice for your situation.

Carry Forward Learning Start here Intern0 XP

Internal Revenue Code · 26 U.S.C.

§ 985. Functional currency

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 985

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status
In force
Added
October 22, 1986 by Pub. L. 99–514
Length
2 subsections · 248 words · about 1 min to read
Defines
1 term
(a) In general

Unless otherwise provided in regulations, all determinations under this subtitle shall be made in the taxpayer’s functional currency.

(b) Functional currency
(1) In general For purposes of this subtitle, the term “functional currency” means—
(A) except as provided in subparagraph (B), the dollar, or
(B) in the case of a qualified business unit, the currency of the economic environment in which a significant part of such unit’s activities are conducted and which is used by such unit in keeping its books and records.
(2) Functional currency where activities primarily conducted in dollars

The functional currency of any qualified business unit shall be the dollar if activities of such unit are primarily conducted in dollars.

(3) Election To the extent provided in regulations, the taxpayer may elect to use the dollar as the functional currency for any qualified business unit if—
(A) such unit keeps its books and records in dollars, or
(B) the taxpayer uses a method of accounting that approximates a separate transactions method.
Any such election shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.
(4) Change in functional currency treated as a change in method of accounting

Any change in the functional currency shall be treated as a change in the taxpayer’s method of accounting for purposes of section 481 under procedures to be established by the Secretary.

(Added Pub. L. 99–514, title XII, § 1261(a), Oct. 22, 1986, 100 Stat. 2585.)

Terms defined here

Where the text says “the term … means”. Select a term to jump to its definition.

Regulations under this section

Treasury regulations (26 CFR) issued under § 985

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 1 other section

Cited by 1 Code section

Cited in 13 regulations not issued under it

Amendment history

From the source credit and the official notes, newest first.

  1. Added by Pub. L. 99–514

Where it sits in the Code

  1. Subtitle A Income Taxes
  2. Chapter 1 NORMAL TAXES AND SURTAXES
  3. Subchapter N Tax Based on Income From Sources Within or Without the United States
  4. Part III INCOME FROM SOURCES WITHOUT THE UNITED STATES
  5. Subpart J Foreign Currency Transactions

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

Effective Date

Pub. L. 99–514, title XII, § 1261(e), Oct. 22, 1986, 100 Stat. 2591, provided that:

“(1) In general.— Except as provided in paragraph (2), the amendments made by this section [enacting this subpart and amending sections 1092 and 1256 of this title] shall apply to taxable years beginning after December 31, 1986.
“(2) Special rules for purposes of sections 902 and 960.— For purposes of applying sections [former] 902 and 960 of the Internal Revenue Code of 1986, the amendments made by this section shall apply to—
“(A) earnings and profits of the foreign corporation for taxable years beginning after December 31, 1986, and
“(B) foreign taxes paid or accrued by the foreign corporation with respect to such earnings and profits.”