Daily Tax Update - December 22, 2016: Foreign Currency Guidance Effective Dates Modified

Foreign Currency Guidance Effective Dates Modified:  Notice 2017-07 modifies the effective dates for the deferral rule under the recently issued special anti-abuse rules under section 987.  The Notice modifies the anti-abuse rules to apply to any deferral or outbound loss event that is undertaken with a principal purpose of recognizing section 987 gain or loss that occurs as a result of an entity classification election made under Treasury Regulations section 301.7701-3 that is filed on or after December 22, and that is effective before December 7.  Additionally, the anti-abuse rules will also apply to any deferral or outbound loss event that occurs as a result of an entity classification election under Treasury Regulations section 301.7701-3 that is filed on or after January 6, 2017 and that is effective before January 6. 

RECENT PUBLICATION

Proposed Regs Modify Device and Active Trade or Business Analysis:  Steptoe's Mark Silverman and Andrew Gordon authored "Proposed Regs Modify Device and Active Trade or Business Analysis" featured in Tax Notes as a special report.  The article discusses the substantial changes in the recently proposed regulations under section 355 that address the device prohibition and the active trade or business requirement.