(a)

(1) through (a)(2) [Reserved]. For further guidance, see §1.988-1(a)(1) through (2).

(3) Specified owner functional currency transactions of a section 987 QBU not treated as section 988 transactions. Specified owner functional currency transactions, as defined in §1.987-3T(b)(4)(ii), held by a section 987 QBU are not treated as section 988 transactions. Thus, no currency gain or loss shall be recognized by a section 987 QBU under section 988 with respect to such transactions.

(4) through (i) [Reserved]. For further guidance, see §1.988-1(a)(4) through (i).

(j) Effective/applicability date. This section applies to taxable years beginning on or after one year after the first day of the first taxable year following December 7, 2016. Notwithstanding the preceding sentence, if a taxpayer makes an election under §1.987-11(b), then this section applies to taxable years to which §§1.987-1 through 1.987-10 apply as a result of such election.

(k) Expiration date. The applicability of this section expires on December 6, 2019.

[T.D. 9795, 81 FR 88879, Dec. 8, 2016]