Regulations Under Section 987; to Simplify Election for Taxpayers with a Qualified Business Unit

SIFMA provides comments to the Internal Revenue Service (IRS) with recommendations to amend the proposed Treasury regulations under Section 987 of the Internal Revenue Code. The change would allow taxpayers to make a one-time election to pay tax on all Section 987 gains or losses annually with respect to a qualified business unit. Such an election would eliminate the significant administrative burden and complexity associated with tracking transfers between the qualified business unit and its owner and tracking untaxed gains and losses of the qualified business unit carried over from previous years.