Recent Regulatory Developments Under Subpart J of the Internal Revenue Code

Monday, January 1st, 1990 at 12:00 am by Daphne Alexander
Daphne Alexander, Recent Regulatory Developments Under Subpart J of the Internal Revenue Code, 1990 Colum. Bus. L. Rev. 239

A comprehensive statutory regime for the U.S. taxation of gains and losses arising from foreign currency exchange rate fluctuations was introduced in the Tax Reform Act of 1986 (the “1986 Act”). A great deal of uncertainty inhered in the taxation of transactions denominated in foreign currencies prior to the enactment of the 1986 Act, due to the ambiguous nature of the relevant sections of the Internal Revenue Code (the “Code”), and to major discrepancies between various conflicting judicial and regulatory determinations. This note provides an overview of the present system governing U.S. taxation of foreign currency transactions and translations.

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