CFC Foreign Currency Gain or Loss (QBU Remittances)

Current understanding

To be populated as evidence accumulates.

2026-08-26 — Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss: cross-connection with cfc-pro-rata-share-subpart-f-tested-income: Both are IRS regulatory actions refining how U.S. shareholders compute CFC income items for current-year U.S. tax. (novelty: 2)
2026-08-14 — Foreign Currency Gain or Loss of Controlled Foreign Corporations: IRS proposed regulations would generally allow controlled foreign corporations to skip computing IRC §987 foreign currency gain or loss on remittances from a qualified business unit, with an exception for certain inbound nonrecognition transactions. (novelty: 2)