Sections 988(c)(1)(D) and (E) require taxpayers to make certain elections which determine whether section 988 applies. In addition sections 988(a)(1)(B) and 988(d) require taxpayers to identify transactions which generate capital gain or loss or which are hedges of other transactions.
US Code:
26 USC 988 (c)(1)(E)
Name of Law: Special rules for certain funds
US Code:
26 USC 988 (c)(1)(D)
Name of Law: Exception for certain instruments marked to market
US Code:
26 USC 988 (a)(1)(B)
Name of Law: Special rule for forward contracts, etc.
US Code:
26 USC 988
Name of Law: Treatment of certain foreign currency transactions
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
INTL-485-89sup.doc
INTL-485-89 (TD 8400 - Final) Taxation of Gain or Loss from Certain Nonfunctional Currency Transactions (Section 988 Transactions)