Wednesday, December 30, 2015

EES: Foreign currency is debt, so says the IRS in this ruling

No comment.

Section 988.--Treatment of Certain Foreign Currency Transactions
An instrument that requires payments to be made in a foreign currency (that is, nonfunctional currency) can be debt for U.S. federal income tax purposes.
Original source from irs.gov:  https://www.irs.gov/pub/irs-drop/rr-08-1.pdf