Internal Revenue Code · 26 U.S.C.
§ 987. Branch transactions
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. § 987
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
- Last amended
- November 10, 1988 by Pub. L. 100–647
- Amendments
- 1 dated changes in the source credit
- Length
- 3 subsections · 174 words · about 1 min to read
- Cross-references
- cites 0; cited by 1 Code section and 15 other regulations
- Regulations
- 20 issued under this section
(Added Pub. L. 99–514, title XII, § 1261(a), Oct. 22, 1986, 100 Stat. 2586; amended Pub. L. 100–647, title I, § 1012(v)(1)(B), Nov. 10, 1988, 102 Stat. 3528.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 987
- § 1.987-0 Table of contents.
- § 1.987-1 Scope, definitions, and special rules.
- § 1.987-1T Scope, definitions, and special rules (temporary).
- § 1.987-2 Attribution of items to eligible QBUs; definition of a transfer and related rules.
- § 1.987-3 Determination of section 987 taxable income or loss of an owner of a section 987 QBU.
- § 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.
- § 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.
- § 1.987-13 Suspended section 987 loss upon terminations.
- § 1.987-14 Section 987 hedging transactions.
- § 1.987-15 Applicability date.
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
Cited by 1 Code section
Cited in 15 regulations not issued under it
- § 1.861-9 Allocation and apportionment of interest expense and rules for asset-based apportionment.
- § 1.861-9T Allocation and apportionment of interest expense (temporary).
- § 1.861-20 Allocation and apportionment of foreign income taxes.
- § 1.904-4 Separate application of section 904 with respect to certain categories of income.
- § 1.905-3 Adjustments to U.S. tax liability and to current earnings and profits as a result of a foreign tax redetermination.
- § 1.985-1 Functional currency.
- § 1.985-5 Adjustments required upon change in functional currency.
- § 1.985-7 Adjustments required in connection with a change to DASTM.
- § 1.985-8 Special rules applicable to the European Monetary Union (conversion to euro).
- § 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).
- § 1.988-2T Recognition and computation of exchange gain or loss (temporary).
- § 1.1502-13 Intercompany transactions.
- § 1.1503(d)-5 Attribution of items and basis adjustments.
Amendment history
From the source credit and the official notes, newest first.
- Amended by Pub. L. 100–647
- Added by Pub. L. 99–514
Where it sits in the Code
- Subtitle A Income Taxes
- Chapter 1 NORMAL TAXES AND SURTAXES
- Subchapter N Tax Based on Income From Sources Within or Without the United States
- Part III INCOME FROM SOURCES WITHOUT THE UNITED STATES
- Subpart J Foreign Currency Transactions
Nearby sections
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Amendments
1988—Par. (4). Pub. L. 100–647 struck out par. (4) which provided for translation of foreign income taxes paid by each qualified business unit of the taxpayer in the same manner as provided under section 986(b).
Statutory Notes and Related Subsidiaries
Effective Date of 1988 Amendment
Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
Effective Date
Section applicable to taxable years beginning after Dec. 31, 1986, with certain exceptions and qualifications, see section 1261(e) of Pub. L. 99–514, set out as a note under section 985 of this title.