Читать книгу International Taxation - Adnan Islam - Страница 48

Section 985 states that, unless it is otherwise provided in the regulations, all determinations for income tax purposes must be made in the taxpayer’s functional currency. A functional currency is the currency of the economic environment in which a significant part of a QBU’s activities are conducted. If the QBU’s activities are primarily conducted in U.S. dollars, the unit’s functional currency is the U.S. dollar. To the extent provided by regulations, a taxpayer may also elect to use the dollar as the functional currency of a QBU if that unit keeps its books in U.S. dollars or uses a method of accounting that approximates a separate transactions method.