ii) and (iii) of this section. The owner shall translate any net unrecognized section 987 gain or loss determined under.987-4 from its old functional currency into its new functional currency using the new functional currency/old functional currency spot exchange rate on the last day of the taxable year ending before. The Foreign Exchange Exposure Pool Method. (c) Coordination with subchapter K (1) Partners adjusted basis in its partnership interest (i) In general. Generally, use of the 1991 proposed section 987 regulations method (see, Examples 1 and 3.987-10(d) or an earnings only section 987 method (see, Example 2.987-10(d) will be considered a reasonable method for purposes.987-10.
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(C) Because Y and Business A have different functional currencies, Ys portion of the Business A assets and liabilities (including the property contributed by Y that is used in Business A) constitutes a section 987 QBU. The end of year functional currency amount of assets shall be determined by reference to the functional currency amount of assets computed under.987-4(d 1 i A) and (e) on the last day of the current taxable year. DE1 owns Business A and the interests in DE2. Therefore, X, and these QBUs, are subject to section 987. For qualified open-loop biomass facilities placed in service after August 8, 2005, 45(b 4 B iii) provides that the 10-year credit period in 45(a 2 A ii) applies.