Foreign Currency Gains/Losses A branch is a qualified business unit (QBU), defined under Sec.
What does QBU stand for?
QBU stands for Qualified Business Unit
This definition appears somewhat frequently and is found in the following Acronym Finder categories:
- Business, finance, etc.
See other definitions of QBU
We have 1 other meaning of QBU in our Acronym Attic
- Quality Backing Tracks
- Quality Business Transport Europe
- Quantitative Bleeding Time
- Queensland Building Tribunal (Australia)
- Query by Template (databases)
- Quilt Bubinga Top (Fender Showmaster guitar component)
- Quota Book Transmittal (US DHS)
- Quebec Business Teachers Association (Canada)
- Qatar Banking Training Institute
- Quadrillion British Thermal Units
- Query Based Update
- Quilting Books Unlimited (mail order bookstore)
- Qualified Business Venture (North Carolina)
- Quality by Vision Ltd.
- Quantum Barrier Varactor
- Query-Based View
- Quantum Barrier Varactor Diode
- Queen's Bench Seven (movie)
- Queensland Beach Volleyball Tour (Australia)
- Quality Builders Warranty Corporation
Samples in periodicals archive:
The Institute's tax executive committee submitted recommendations on IRS-proposed revisions to section 987 of the Internal Revenue Code that require a taxpayer to recognize exchange gain or loss--upon receiving a remittance from a qualified business unit (QBU)--by apportioning its basis in the QBU to each remittance and then recognizing exchange gain or loss based on the difference between the value of the remittance and the basis apportioned to it (www.
In this regard, the AICPA offered comments on qualified business units (QBUs) that are branches, including disregarded entities.
IRS personnel have publicly suggested that the looming introduction of the new European currency, the euro, probably should be treated as a change in functional currency and a change in accounting method for qualified business units (QBUs) that convert.
This approach also accords with the 1986 enactment of section 988(a)(3), which generally provides that the source of any foreign currency gain or loss attributable to a section 988 transaction is determined by reference to the taxpayer's residence or the taxpayer's qualified business unit on whose books the asset is properly reflected.
985-1(b)(2)(ii)(E) requires that a qualified business unit (QBU) that has elected or been required to use the dollar as its functional currency under DASTM must change its functional currency as of the first day of the first taxable year that follows three consecutive taxable years in which the currency of its economic environment, determined under paragraph (c)(2) of this section, is not a hyperinflationary currency.
Burke referred to the 1991 proposed regulations concerning the proper computation of income and earnings and profits under the dollar approximate separate transactions method (DASTM) for qualified business units operating in countries affected by hyperinflationary currencies.
We suggest, however, that such treatment also be permitted for (1) hedges entered into by an entity other than the entity with the underlying exposure; (2) hedges entered into prior to fixing the right " obligation with respect to the underlying hedged item; and (3) hedges and related underlying transactions not recorded on the books of the same qualified business unit.