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ARTICLE · 30 JULY 2026

IRS Releases Final Forms For Section 987 Reporting And Elections

MGO CPA LLP
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The forms support the final Section 987 regulations issued in December 2024, which provide guidance for determining taxable income, loss, and earnings and profits for qualified business units (QBUs) that use a different functional currency than their owners. The regulations apply to tax years beginning in 2025.

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Macias Gini & O'Connell
Macias Gini & O'Connell
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Key Takeaways:

  • The IRS released final Forms 8964-ELE and 8964-TRA for taxpayers subject to the Section 987 regulations.
  • Section 987 elections made for 2025 can have lasting implications and may limit election opportunities in future tax years.
  • Taxpayers should review filing requirements early to meet election deadlines and transition reporting obligations.

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The IRS has released final Forms 8964-ELE and 8964-TRA, which affected taxpayers must use beginning with the 2025 tax year.

The forms support the final Section 987 regulations issued in December 2024, which provide guidance for determining taxable income, loss, and earnings and profits for qualified business units (QBUs) that use a different functional currency than their owners. The regulations apply to tax years beginning in 2025.

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