# Prop. Treas. Reg. § 1.987-17: Applicability date.

Proposed regulation, not in force. REG-103844-26, 91 FR 52553, published 2026-08-14 <https://www.federalregister.gov/documents/2026/08/14/2026-16569/foreign-currency-gain-or-loss-of-controlled-foreign-corporations>. Interprets 26 U.S.C. § 987.

Par. 9. Newly redesignated § 1.987-17 is amended by adding paragraphs (e) and (f) to read as follows:

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(e) Applicability date of 120-month amortization rule. Section 1.987-10(e)(5)(ii) applies to taxable years beginning after December 31, 2024, and ending on or after November 25, 2025. See § 1.987-15, as contained in 26 CFR in part 1 in effect on April 1, 2025, for a prior applicability date for § 1.987-10(e)(5)(ii).

(f) Applicability date of rules relating to the CFC exemption election. Sections 1.987-1(g)(2)(iv) and (g)(3)(ii)(D), 1.987-6(b)(1)(v) and (vi), 1.987-7(b)(2), (c)(2)(iv), and (d)(2)(iv), and 1.987-15 apply to taxable years ending on or after [date of filing of final regulations with the Federal Register ]. Section 1.987-16 applies to transactions completed within taxable years of a domestic acquiring corporation ending on or after [date of filing of final regulations with the Federal Register ]. See § 1.987-15, as contained in 26 CFR in part 1 in effect on April 1, 2025, for a prior applicability date for § 1.987-7(b).