Читать книгу International Taxation - Adnan Islam - Страница 65

If a branch changes its functional currency from a legacy currency to the euro when the taxpayer’s functional currency is not the euro, no adjustment to the currency basis pool is necessary. The branch’s euro equity pool is simply the product of the legacy currency and the appropriate exchange rate. However, if a branch changes its functional currency from a legacy currency to the euro for a taxable year during which the taxpayer’s functional currency is the euro, the taxpayer realizes gain or loss attributable to the branch’s unremitted earnings computed as if the branch terminated on the last day prior to the year of change. This amount is recognized ratably over four years beginning with the taxable year of change.