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Treasury Decision 8914 - Definition Of Hyperinflationary Currency For Purposes Of Section 988
Get Treasury Decision 8914 - Definition Of Hyperinflationary Currency For Purposes Of Section 988
Rt 1 Definition of Hyperinflationary Currency for Purposes of Section 988 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains final regulations concerning when a currency will be considered hyperinflationary for purposes of section 988. These final regulations are intended to prevent distortions associated with the computation of income and expense arising from section 988 transactions denominated in hyperinflationary currencies. DATES: Th.
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Hyperinfla FAQ
A loss from a foreign currency transaction under Internal Revenue Code section 988 is a loss transaction if the gross amount of the loss is at least $50,000 in a single tax year for individuals or trusts, whether or not the loss flows through from an S corporation or partnership.
988 treats most (but not all) gains and losses from foreign currency transactions as ordinary in character.
If you did NOT elect out of IRC 988, the gain or (loss) would be subject to IRC 988. You would enter the information on Schedule 1 (Form 1040) Additional Income and Adjustments to Income, Line 8 as an ordinary gain or (loss).
Yes, an individual or a trust with an IRC §165 loss that arose from a single IRC § 988 transaction of $50,000 or more in a single taxable year has a disclosure requirement.
Except as otherwise provided in this section, any foreign currency gain or loss attributable to a section 988 transaction shall be computed separately and treated as ordinary income or loss (as the case may be).
Section 988 applies to transactions denominated in nonfunctional currencies involving the acquisition of or assumption of an obligation for a debt instrument; transactions involving the accrual of items of gross income, expense, or receipts that are paid or received after the accrual date; and derivatives or similar ...
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