Foreign Currency Gain or Loss of Controlled Foreign Corporations

Open for public comment until Nov. 12, 2026. Comment on Regulations.gov

What it does

This document contains proposed regulations providing rules relating to the determination and recognition of foreign currency gain or loss with respect to qualified business units ("QBUs") of controlled foreign corporations ("CFCs"). The proposed regulations provide an election under which a CFC generally would not be required to compute or recognize foreign currency gain or loss upon a remittance from a QBU, except in connection with certain inbound nonrecognition transactions.

The Internal Revenue Service's summary, as published in the Federal Register.

What it would change

1 part of Title 26 of the Code of Federal Regulations:

26 CFR 1

Before this

No earlier Federal Register document under regulation identifier 1545-BS16 since Jan. 1, 2025.

What happens next and when

Written or electronic comments and requests for a public hearing must be received by November 12, 2026.

The agency's dates, word for word.

Check it yourself

• The document in the Federal Register
• Docket IRS-2026-0958 on Regulations.gov
• Title 26 on eCFR

The record as published

Source: the Federal Register (public domain). The document in the Federal Register