(a) through (c) [Reserved]. For further guidance, see §1.987-8(a) through (c).

(d) Annual deemed termination election. A taxpayer, including a taxpayer described in §1.987-1(b)(1)(ii) to which §§1.987-1 through 1.987-11 generally do not apply, may elect under this paragraph (d) to deem all of the section 987 QBUs of which it is an owner to terminate on the last day of each taxable year for which the election is in effect. See §1.987-8(e) regarding the effect of such a deemed termination. The owner of a section 987 QBU that is deemed to terminate under this paragraph is treated as having transferred all of the assets and liabilities attributable to such section 987 QBU to a new section 987 QBU on the first day of the following taxable year.

(e) through (f) [Reserved]. For further guidance, see §1.987-8(e) through (f).

(g) Effective/applicability date. This section applies to taxable years beginning on or after December 7, 2016.

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

[T.D. 9795, 81 FR 88875, Dec. 8, 2016]