Читать книгу International Taxation - Adnan Islam - Страница 64

Taxpayers may determine that the benefit of deferral is not worth the administrative costs associated with tracking exchange gains and losses on large quantities of trade accounts. A taxpayer may elect to recognize exchange gains and losses on all accounts receivable and payable immediately prior to the year of change. The affected taxpayer must attach a statement to its tax return for the taxable year of change, which includes the following: “Taxpayer certifies that a QBU of the taxpayer has elected to realize currency gain or loss on legacy currency-denominated accounts receivable and payable upon change of functional currency to the euro.” A QBU making this election must do so for all its legacy currency denominated Section 988 transactions.