EYEY

US IRS issues new proposed regulations that limit or modify taxpayers' ability to make or revoke certain foreign currency elections

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United States

  • The proposed regulations modify the timing within which a foreign currency mark-to-market election can be made or revoked, likely preventing taxpayers from making or revoking a Prop. Treas. Reg. Section 1.988-7 election for the 2023 and 2024 tax years.
  • The proposed regulations align the procedures for making Treas. Reg. Section 1.954-2(g) elections with other elections made on behalf of calendar ye…

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