Temp foreign currency regs cover gain or loss for terminated qualified business units

IRS has issued temporary regs on the recognition and deferral of foreign currency gain or loss under Code Sec. 987 with respect to a qualified business unit (QBU) in connection with a QBU's termination and certain transactions involving partnerships. The temporary regs also provide an annual deemed termination election with an elective yearly average exchange rate method, and other rules for a Code Sec. 987 QBU, as well as rules on the treatment of Code Sec. 988 transactions, dollar QBUs, and related party loans. The text of the temporary regs serve as the text of proposed regs. … Read More

Congress passes bill exempting small employer HRAs from ACA group plan rules

The Senate on December 7 passed, by a 94-5 vote, H.R. 34, the "21st Century Cures Act" (the Act) which was passed by the House of Representatives on November 30 by a 392-26 margin. The Act covers a wide-ranging group of nontax health subjects and also includes a provision exempting small employer health reimbursement arrangements (HRAs) from the Affordable Care Act (ACA)'s group plan rules. The Act is expected to be signed into law by President Obama. … Read More