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Example 2-16

Оглавление

X, a calendar-year corporation whose functional currency is the dollar, entered into a forward contract on October 1, 20X1, to purchase Q100,000 for delivery on March 1, 20X2. The six-month forward rate was $.4907. On March 1, 20X2, X takes delivery of the Q100,000 when the spot rate is $.48. X is treated as if it sold the contract for its fair market value when it takes delivery of nonfunctional currency under the forward contract. Therefore, X has an exchange loss of $1,070 ([$.48 × Q100,000] − [$.4907 × Q100,000]) and a basis of $48,000 in the Q100,000 (Treasury Regulation 1.988-2(d)(4)(iii), example (1)).

International Taxation

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