Читать книгу International Taxation - Adnan Islam - Страница 77

In general, foreign currency gain or loss attributable to a Section 988 transaction is computed separately and treated as ordinary income or loss. Capital gain or loss treatment may be elected for forward contracts, futures contracts, and options that constitute capital assets in the hands of the taxpayer that are not marked to market, are not parts of a tax straddle, and meet the identification requirements. In some Section 988 transactions, foreign currency gain or loss will be treated as interest income or expense.