Читать книгу International Taxation - Adnan Islam - Страница 70

Generally, the recognition of gain or loss upon the sale or other disposition of nonfunctional currency is governed by the recognition provision in the IRC that applies to the sale or disposition of property. With respect to Section 1031, a nonfunctional currency exchange is not considered “like kind” property. However, the following transactions are not considered recognition events:

 An exchange of units of nonfunctional currency for different units of the same nonfunctional currency

 The deposit of nonfunctional currency in a demand or time deposit, or similar instrument (such as a certificate of deposit [CD]) issued by a bank or other financial institution if such instrument is denominated in such currency

 The withdrawal of nonfunctional currency from a demand or time deposit or similar instrument if such instrument is denominated in such currency

 The receipt of nonfunctional currency from a bank or other financial institution from which the taxpayer purchased a certificate of deposit or similar instrument denominated in such nonfunctional currency, by reason of the maturing or other termination of such instrument

 The transfer of nonfunctional currency from a demand or time deposit or similar instrument issued by a bank or other financial institution to another demand or time deposit or similar instrument denominated in the same nonfunctional currency issued by a bank or other financial institution.