This outline provides a plain English summary of the tax provisions of subpart J of the Code governing the taxation of foreign currency gain or loss arising in international operations, including non-functional currency debt instruments and other section 988 transactions, translation of branch remittances under Section 987, exchange gain or loss with respect to distributions of previously-taxed income (PTI), and taxation of a CFC's exchange gain or loss, and also reviews a number of practical issues that commonly arise in the foreign currency taxation area.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
