# Foreign Currency Gain or Loss of Controlled Foreign Corporations

**Action Urgency Score:** 55/100

| Field | Value |
|---|---|
| Agency | Treasury Department; Internal Revenue Service |
| Type | Proposed rule |
| Action | Notice of proposed rulemaking. |
| Published | 2026-08-14 |
| Comments close | 2026-11-12 |
| Significant | No |
| CFR parts | 26 CFR 1 |
| Summary | This document contains proposed regulations providing rules relating to the determination and recognition of foreign currency gain or loss with respect to qualified business units ("QBUs") of controlled foreign corporations ("CFCs"). The proposed regulations provide an election under which a CFC generally would not be required to compute or recognize foreign currency gain or loss upon a remittance from a QBU, except in connection with certain inbound nonrecognition transactions. |
| Document number | 2026-16569 |

## Why this score
- Comment deadline within 30 days.

Source: Federal Register API (Office of the Federal Register) (https://www.federalregister.gov/documents/2026/08/14/2026-16569/foreign-currency-gain-or-loss-of-controlled-foreign-corporations). Last refreshed: 2026-11-04T09:17:43.641Z.
Data from the Federal Register API; the published Federal Register document is authoritative. Informational only, not legal advice.