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Aggregate or Entity Theory of Partnerships for Currency?

John D. Bates
Tax Notes International

This article tackles the conceptually difficult area of how partnerships with foreign operations should be treated under sections 987 and 988, the primary operative foreign currency provisions.  It argues that the policies behind these currency provisions and partnership tax principles support an entity approach, making the case that the functions of sections 987 and 988 are best carried out at the partnership – as opposed to the partner – level.

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