# Prop. Treas. Reg. § 1.987-6: Character and source of section 987 gain or loss.

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. 4. Section 1.987-6 is amended by adding paragraphs (b)(1)(v) and (vi) to read as follows:

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(b) * * *

(1) * * *

(v) In the case of net unrecognized section 987 gain or loss that is recognized as pre-election section 987 gain or loss under § 1.987-15(e)(3), the taxable year immediately preceding the first taxable year in which the CFC exemption election applies.

(vi) The taxable year in which the amount of section 987 asset basis is recognized under § 1.987-16(d).

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