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987
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| taxpayer's "Section 987
qualified business unit" ("Section 987 QBU"). 987 regulations require the recognition
of the currency gain on capital by the U. The Institute's tax executive committee submitted
recommendations on IRS-proposed revisions to section 987 of the Internal
Revenue Code that require a taxpayer to recognize exchange gain or
loss--upon receiving a remittance from a qualified business unit
(QBU)--by apportioning its basis in the QBU to each remittance and then
recognizing exchange gain or loss based on the difference between the
value of the remittance and the basis apportioned to it
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