# Prop. Treas. Reg. § 1.987-11: Suspended section 987 loss relating to certain elections; loss-to-the-extent-of-gain rule.

Proposed regulation, not in force. REG-115145-25, 91 FR 48794, published 2026-08-03 <https://www.federalregister.gov/documents/2026/08/03/2026-15614/section-898c-transition-rule-for-allocating-foreign-taxes-and-section-960d4-foreign-tax-credit>. Interprets 26 U.S.C. § 987.

Par. 9. Section 1.987-11 is amended by revising paragraph (c)(3)(ii) to read as follows:

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(c) * * *

(3) * * *

(ii) Owner is a CFC. For purposes of applying paragraph (c)(2) of this section with respect to an owner that is a CFC, suspended section 987 loss and gross income of a member of the owner's controlled group is determined by reference to the member's suspended section 987 loss and gross income for its taxable year ending with or within the owner's required year described in section 898(c)(1).

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