Forms, Schedules, and Instructions for U.S. Tax-Exempt Returns

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2025

Instructions for Form
8964-ELE
Section 987 Elections
Section references are to the Internal Revenue Code
unless otherwise noted.

Future Developments

For the latest information about developments related to
Form 8964-ELE and instructions, such as legislation
enacted after they were published, go to IRS.gov/
Form8964ELE.

On December 11, 2024, final regulations were issued
under section 987 of the Internal Revenue Code (TD
10016, 89 FR 100138). Section 987 applies to any
taxpayer that has a qualified business unit with a
functional currency other than the dollar. The section 987
regulations provide rules for determining and translating
taxable income or loss with respect to the QBU. In
addition, the regulations provide rules for calculating
foreign currency gain or loss under section 987(3), which
requires proper adjustments for transfers of property
between QBUs of the taxpayer having different functional
currencies.

General Instructions
Purpose of Form

Form 8964-ELE is used to make or revoke elections under
the section 987 regulations. The form is used to satisfy the
reporting requirements of Regulation section 1.987-1(g).

Who Must File

A section 987 election is made or revoked for an owner of
a section 987 QBU by the authorized person (each as
defined below).

When and Where To File

The authorized person must attach Form 8964-ELE with
its original, timely filed (including extensions) return for the
tax year for which the elections are made. As explained
below, additional requirements apply in certain tax years
and for certain elections.

First year in which the section 987 regulations apply.
There are no additional requirements for the first tax year
that the section 987 regulations apply to an owner or the
first tax year in which the owner or any member of its
consolidated group or section 987 electing group is the
owner of a section 987 QBU. For that year, section 987
elections are made by attaching Form 8964-ELE to the
taxpayer’s original, timely filed return.
Subsequent years—current rate election, annual recognition election, or section 988 mark-to-market
Dec 4, 2025

Subsequent years—other section 987 elections. In
subsequent years, a current rate election, annual
recognition election, or section 988 mark-to-market
election can be made or revoked only with the
Commissioner’s consent. Taxpayers can obtain consent to
make or revoke an election by requesting a private letter
ruling pursuant to Rev. Proc. 2025-1, 2025-1 IRB 1 or its
successor. A copy of the ruling must be attached with
Form 8964-ELE to the taxpayer’s original, timely filed
return for the tax year for which the elections are made.
See Summary of Section 987 Election Filing
Requirements, Application of First Year and Subsequent
Year Regulations, later for additional information on how to
make section 987 elections.

Consistency Requirements

In general, a section 987 election is made for an owner
and for a taxable year and applies to every section 987
QBU owned by the owner while the election is in effect.
Once made, a section 987 election remains in effect until
revoked.
In the case of a consolidated group, a section 987
election is made or revoked by a consolidated group and
applies to all members of the group. Therefore, the same
section 987 elections will be in effect for all members of a
consolidated group at all times. If a corporation becomes
a member of a consolidated group, it is deemed to make
or revoke any section 987 election as necessary to be
consistent with the consolidated group. If a corporation
ceases to be a member of a consolidated group and does
not join another group, its section 987 elections are

Instructions for Form 8964-ELE (2025) Catalog Number 95736X
Department of the Treasury Internal Revenue Service www.irs.gov

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What’s New

election. To make or revoke a current rate election,
annual recognition election, or section 988 mark-to-market
election for a subsequent year, the authorized person
must file Form 8964-ELE before the start of the tax year
for which the elections are made. For this purpose, the
Form 8964-ELE must be sent to the e-Fax number
provided in Filing Form 8964-ELE, later. The authorized
person must also attach Form 8964-ELE to its original,
timely filed return for the tax year for which the election is
made.
Once made, a current rate election, annual recognition
election, or section 988 mark-to-market election may not
be revoked without the Commissioner's consent for any
taxable year beginning within 60 months of the first day of
the taxable year for which it was made. Once revoked, a
new election may not be made without the
Commissioner's consent for any taxable year beginning
within 60 months of the first day of the taxable year for
which it was revoked.

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unaffected by its departure from the group. See
Regulations section 1.987-1(g)(2)(i).
In addition, all members of the same section 987
electing group (defined below) must make or revoke
section 987 election consistently. If an entity becomes a
member of a section 987 electing group (for example,
upon formation or acquisition), it is deemed to make or
revoke any section 987 election as necessary to be
consistent with the other members of the group. See
Regulations section 1.987-1(g)(2)(ii).

Definitions
QBU

A qualified business unit (QBU) generally is defined as
any separate and clearly identified unit of a trade or
business of a taxpayer provided that separate books and
records are maintained. See Regulations section
1.989(a)-1(b). For this purpose, a corporation,
partnership, trust, estate, or disregarded entity is not itself
a QBU, but the activities of such an entity may be a QBU.
A section 987 QBU is an eligible QBU that has a
functional currency different from that of its owner. An
eligible QBU means a QBU that is not subject to the
United States dollar approximate separate transactions
method (DASTM) rules of Regulations section 1.985-3.
An owner generally may elect to treat all section 987
QBUs with the same functional currency as a single
section 987 QBU.

Owner of a Section 987 QBU (or “QBU Owner”)

The owner of a section 987 QBU (or “QBU owner”)
generally is the person who is treated as owning the
assets and liabilities of the section 987 QBU for Federal
income tax purposes. A section 987 QBU cannot be the
owner of another section 987 QBU. For example, if DC (a
domestic corporation) owns QBU1 (a section 987 QBU),
and QBU1 wholly owns the disregarded entity that owns
QBU2 (another section 987 QBU), QBU1 is not the owner
of QBU2. Instead, DC is the owner of both QBU1 and
QBU2.

The following persons can be the owner of a section
987 QBU.
• A U.S. person.
• A controlled foreign corporation (CFC).
• A U.S. partnership.
• A foreign partnership (FP).

U.S. Person

A U.S. person includes:
• A citizen or resident alien of the United States (see Pub.
519, About Publication 519, U.S. Tax Guide for Aliens,
available at IRS.gov/Pub519, for guidance on determining
resident alien status);
• A domestic partnership; and
• A domestic corporation.

2

A controlled group means all persons with the
relationships to each other specified in section 267(b) or
section 707(b).

Authorized Person

With respect to the owner of a section 987 QBU, the
“authorized person” is the person that makes section 987
elections for the owner. The authorized person is defined
as follows.
• If the owner is a U.S. person, the owner is the
authorized person.
• If the owner is a CFC, the controlling domestic
shareholders (determined under Regulations section
1.964-1(c)(5)(i)) of the CFC are treated as the authorized
person. If there are multiple controlling domestic
shareholders, references to the “authorized person” refer
to all controlling domestic shareholders acting in concert.
• If the owner is a member of a consolidated group, the
election is made by the common parent or other agent for
the consolidated group. See Regulations section
1.1502-77.
• If the owner is a partnership, the election is made or
revoked by the partnership. For a partnership that is not
otherwise required to file a partnership return, see
Regulations section 1.6031(a)-1(b)(5) for elections that
can only be made by a partnership under section 703.
For more information, see Regulations section
1.987-1(g)(1).

Section 987 Elections

A section 987 election is an election provided in the
section 987 regulations. The following elections are
section 987 elections.
• Current rate election (Regulations section 1.987-1(d)
(2)): An election to treat all items of a section 987 QBU as
marked items.
• Annual recognition election (Regulations section
1.987-5(b)(2)): An election to recognize all of the net
unrecognized section 987 gain or loss with respect to a
section 987 QBU on an annual basis.
• Section 988 mark-to-market election (Regulations
section 1.987-3(b)(4)(ii)): An election to recognize section
988 gain or loss of a section 987 QBU under a
mark-to-market method of accounting.
• Section 987 grouping election (Regulations section
1.987-1(b)(3)(ii)): An election to treat all section 987 QBUs
of the same owner that have the same functional currency
as a single section 987 QBU.
• Election to use a spot rate convention (Regulations
section 1.987-1(c)(1)(ii)): An election to determine the
spot rate using a spot rate convention.
• Election to use the historic inventory method
(Regulations section 1.987-3(c)(2)(iv)(B)): An election to
account for inventory of a section 987 QBU using historic
exchange rates.
• Amortization election – transition rules (Regulations
section 1.987-10(e)(5)(ii)(A)): An election to recognize
pretransition gain or loss ratably over a period of ten
years.
• Small business election – transition rules (Regulations
section 1.987-10(e)(7)(iv)): An election for small
businesses to treat pretransition gain or loss as zero.

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Section 987 QBU

Controlled Group

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• Section 988 characterization election (Regulations
section 1.987-6(b)(2)(i)(C)(1)): An election to characterize
passive category section 987 gain or loss of a CFC as
foreign currency gain or loss from section 988
transactions for subpart F purposes.
• Recurring transfer group election (Proposed
Regulations section 1.987-2(f)(1)): An election to use an
average exchange rate to translate assets that are
transferred between a section 987 QBU and its owner as
part of a recurring transfer group.
Section 987 Electing Group

A section 987 electing group includes a U.S. person and
any of the following entities.
• Each CFC in which the U.S. person owns (within the
meaning of section 958(a)) more than 50% of the stock
(by vote or value).
• Each foreign partnership in which the U.S. person owns
(directly or indirectly) more than 50% of the capital and
profits interest.
For more information, see Regulations section
1.987-1(g)(2)(ii).
Spot rate generally means a rate that reflects a fair market
rate of exchange available to the public for currency under
a spot contract in a free market and involving
representative amounts.
An owner may elect to use a spot rate convention that
reasonably approximates the spot rate based on the spot
rate at the beginning of a reasonable period, the spot rate
at the end of a reasonable period, the average of spot
rates for a reasonable period, or spot and forward rates for
a reasonable period. A reasonable period cannot exceed
three months.

Historic Rate

The historic rate for an asset other than inventory
generally is the yearly average exchange rate applicable
to the year of acquisition. For depreciable or amortizable
property, the historic rate may be determined by reference
to the date the property is placed in service.
The historic rate for LIFO inventory generally is the
yearly average exchange rate applicable to the year in
which the inventory’s LIFO layer arose. The historic rate
for non-LIFO inventory generally is the yearly average
exchange rate for the relevant tax year. See Regulations
sections 1.987-1(c)(3)(i)(B) and (C).
The historic rate for a liability is the yearly average
exchange rate applicable to the year the liability is
incurred or assumed.

The yearly average exchange rate is a rate that represents
an average exchange rate for the tax year (or, if the
section 987 QBU existed for less than the full tax year, the
portion of the year during which the section 987 QBU
existed) computed under any reasonable method.

Marked Item

In general, a marked item is an asset (marked asset) or
liability (marked liability) that is attributable to a section
987 QBU and falls into one of the following categories.
• The item is denominated in, or determined by reference
to, the functional currency of the section 987 QBU and
would be a section 988 transaction if such item were held
or entered into directly by the owner of the section 987
QBU;
• The item is a prepaid expense or a liability for an
advance payment of unearned income, in either case
having an original term of one year or less on the date the
prepaid expense or liability for an advance payment of
unearned income arises;
• The item is a section 988 transaction of the section 987
QBU;
• The item is an insurance reserve; or
• The item is a separate account asset.
However, a taxpayer may elect to treat all assets and
liabilities that are attributable to a section 987 QBU as
marked items (a current rate election).

Historic Item

A historic item is an asset (historic asset) or liability
(historic liability) that is attributable to a section 987 QBU
and that is not a marked item.

Combination

A combination occurs when the assets and liabilities that
were attributable to two or more section 987 QBUs
(referred to as the combining QBUs) become attributable
to one section 987 QBU (referred to as the combined
QBU) and the separate existence of the combining QBUs
ceases.

Separation

A separation occurs when the assets and liabilities that
were attributable to a section 987 QBU (referred to as the
separating QBU) begin to be attributable to two or more
section 987 QBUs (referred to as the separated QBUs)
and each of the separated QBUs continues to perform a
significant portion of the separating QBU's activities
immediately after the separation.

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Spot Rate

Yearly Average Exchange Rate

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Summary of Section 987 Election Filing Requirements, Application of First Year and Subsequent Year
Regulations
First Year Regulations
Apply

Subsequent Years

Section 987 Current Rate Election under Regulations
section 1.987-1(d)(2)

On timely filed return
(including extensions)

Before the start of the tax year and on timely filed
return (including extensions)

Section 987 Annual Recognition
Regulations section 1.987-5(b)(2)

On timely filed return
(including extensions)

Before the start of the tax year and on timely filed
return (including extensions)

Section 988 Mark-To-Market Election under Regulations
section 1.987-3(b)(4)(ii)

On timely filed return
(including extensions)

Before the start of the tax year and on timely filed
return (including extensions)

Section 987 Grouping Election under Regulations section
1.987-1(b)(3)(ii)

On timely filed return
(including extensions)

Only with consent—on timely filed return
(including extensions)

Election to use a Spot Rate Convention under Regulations
section 1.987-1(c)(1)(ii)

On timely filed return
(including extensions)

Only with consent—on timely filed return
(including extensions)

Election to use the Historic Inventory Method under
Regulations section 1.987-3(c)(2)(iv)(B)

On timely filed return
(including extensions)

Only with consent—on timely filed return
(including extensions)

Election to Characterize Certain Section 987 Gain/(Loss) as
Foreign Currency Gain/(Loss) from Section 988
Transactions under Regulations section 1.987-6(b)(2)(i)(C)
(1)

On timely filed return
(including extensions)

Only with consent—on timely filed return
(including extensions)

Recurring Transfer Group Election under Proposed
Regulations section 1.987-2(f)(1)

On timely filed return
(including extensions)

Only with consent—on timely filed return
(including extensions)

Amortization Election in the Transition Rules under
Regulations section 1.987-10(e)(5)(ii)(A)

On timely filed return
(including extensions)

N/A (election can only be made in the first year)

Small Business Election in the Transition Rules under
Regulations section 1.987-10(e)(7)(iv)

On timely filed return
(including extensions)

N/A (election can only be made in the first year)

Election

under

Filing Form 8964-ELE

For elections that must be filed before the start of the year
(for subsequent years after the first year the 987
regulations apply), e-Fax Form 8964-ELE to
833-312-2650 and file a copy with your timely filed return.

Additional Filing Requirements
Form 8964-TRA. An owner of a QBU is required to
compute pretransition gain or loss with respect to each
section 987 QBU, deferral QBU, and outbound loss QBU
under Regulations section 1.987-10(e) by filing Form
8964-TRA, Section 987 Transition Information. See the
instructions to Form 8964-TRA, available at IRS.gov/
Form8964TRA.
Form 8858. U.S. persons that operate a foreign branch or
own a foreign disregarded entity directly or, in certain
circumstances, indirectly or constructively may be
required to file Form 8858, Information Return of U.S.
Persons With Respect to Foreign Disregarded Entities
(FDEs) and Foreign Branches (FBs). For more
information, see IRS.gov/Form8858.

Other Reporting Requirements
Computer-Generated Form 8964–ELE and
Schedules

Generally, all computer-generated forms must receive
prior approval from the IRS and are subject to an annual
review. However, see the Exception below. Requests for
approval may be submitted electronically to
substituteforms@irs.gov, or requests may be mailed to:

4

Internal Revenue Service
Attention: Substitute Forms Program
C:DC:TS:CAR:MP:P:TP
1111 Constitution Ave. NW
Room 6554
Washington, DC 20224
Exception. If a computer-generated Form 8964-ELE
conforms to and does not deviate from the official form
and schedules, they may be filed without prior approval
from the IRS.
Important. Be sure to attach the approval letter to Form
8964-ELE. However, if the computer-generated form is
identical to the IRS-prescribed form, it does not need to go
through the approval process, and an attachment is not
necessary.
Every year, the IRS issues a revenue procedure to
provide guidance for filers of computer-generated forms.
In addition, every year, the IRS issues Pub.1167, General
Rules and Specifications for Substitute Forms and
Schedules, available at IRS.gov/Pub1167, which reprints
the most recent applicable revenue procedure.

Corrections to Form 8964-ELE

If you file a Form 8964-ELE that you later determine is
incomplete or incorrect, file a corrected Form 8964-ELE
with an amended tax return, using the amended return
instructions for the return with which you originally filed
Form 8964-ELE. Enter “Corrected” at the top of the form
and attach a statement identifying the changes.

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Section 987 Election Filing Requirements

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Specific Instructions
Important. If the information required in a given section
exceeds the space provided within that section, do not
enter “See attached” in the section and then attach all of
the information on additional sheets. Instead, complete all
entry spaces in the section and attach the remaining
information on additional sheets. The additional sheets
must conform with the IRS version of that section.

Identifying Information

Name and Identifying Number Of The Person Filing
Form 8964-ELE. Provide the name and identifying
number of the person filing Form 8964-ELE. The filer
typically is the authorized person (see Authorized Person,
earlier). Filers are permitted to enter an EIN or a reference
ID number. The reference ID number must meet the
requirements set forth below.
If the authorized person is a member of a consolidated
group, list the common parent as the person filing the
return and enter its identifying information in the spaces
provided at the top of page 1 of the form.
Name and Identifying Number Of Authorized Person.
If the filer of Form 8964-ELE is not the authorized person,
provide the name and identifying/reference ID number of
the authorized person.
Name change. If the name of the filer or authorized
person changed within the past 3 years, show the prior
name(s) in parentheses after the current name.
Reference ID Number.
Note: There is no need to apply to the IRS to request a
reference ID number or for permission to use these
numbers.
Requirements. The reference ID number must be
alphanumeric (defined below) and no special characters
or spaces are permitted. The length of a given reference
ID number is limited to 50 characters. The same reference
ID number must be used consistently from tax year to tax
year. If, for any reason, a reference ID number falls out of
use, the reference ID number cannot be used again for
another filer for purposes of Form 8964-ELE reporting. For
these purposes, the term “alphanumeric” means the entry
can be alphabetical, numeric, or any combination of the
two. Taxpayers cannot enter “FOREIGNUS” or “APPLIED
FOR” in a column that requests an EIN or reference ID
number. Instead, if an EIN is not available, the filer must
enter a reference ID number that uniquely identifies itself.
Address. Include the suite, room, or other unit number
after the street address. If the post office does not deliver
mail to the street address and the U.S. person has a P.O.
box, show the box number instead.
Foreign address. Enter the information in the following
order: city, province or state, and country. Follow the
country's practice for entering the postal code, if any. Do
not abbreviate the country name.

Part I—Identifying Information Of
Owner and QBU
Section A—Owner Information
Line 1—QBU owner information. Complete lines 1a
through 1g only if the authorized person is not the QBU
owner subject to the section 987 election(s) (for example,
if the authorized person is a U.S. corporation that makes
section 987 elections on behalf of a CFC that is the owner
of a section 987 QBU).
Line 1b—Annual accounting period and tax year of
QBU owner. Enter the annual accounting period of the
QBU owner for which you are furnishing information.
Line 1d(2)—Reference ID number of QBU owner.
Enter the reference ID number of the QBU owner for which
you are furnishing information. Filers are permitted to
enter both an EIN on line 1d(1) and a reference ID number
on line 1d(2).
A “reference ID number” is a number established by or
on behalf of the QBU owner that is assigned to the owner.
These numbers are used to uniquely identify the QBU
owner in order to keep track of the QBU owner from tax
year to tax year. The reference ID number must meet the
requirements set forth above.
Line 1g—Functional currency of QBU owner. The
functional currency of the QBU owner is determined under
section 985. Enter the applicable three-character alphabet
code for the owner's functional currency using the ISO
4217 standard. These codes are available at sixgroup.com/en/products-services/financial-information/
data-standards.html#scrollTo=currency-codes. Click on
List One (XLS).
Line 2—Direct owner information. Complete lines 2a
through 2d only if the authorized person or QBU owner
reported on line 1a is not the direct owner of the section
987 QBUs subject to the election(s) (for example, if the
owner is a CFC that owns a section 987 QBU through one
or more entities that are disregarded for U.S. tax
purposes).

Section B—QBU Information

Enter information for the QBU with respect to which the
section 987 election(s) are being made. Attach a
statement and list information where applicable.
Line 1—QBU information. Enter the name and
identifying number of the QBU (i.e., the name of the
relevant disregarded entity, branch, or trade or business).
The identifying number is the EIN if the section 987
QBU is a disregarded entity. Otherwise, enter the EIN of
the QBU owner. If the owner is a domestic corporation that
is a member of a consolidated group, list the common
parent’s EIN on line 1b(1).

5

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Annual Accounting Period. Enter, in the space
provided below the title of Form 8964-ELE, the annual
accounting period of the person furnishing information.

Multiple Owners Or QBUs. If you are the authorized
person for multiple QBU owners or for an owner with
multiple section 987 QBUs subject to the section 987
elections, check “Yes,” and complete only Part II.
Otherwise, check “No,” and complete only Part I.

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Filers are permitted to enter both an EIN on line 1b(1)
and a reference ID number on line 1b(2). A “reference ID
number” is a number established by or on behalf of the
QBU that is assigned to the QBU. These numbers are
used to uniquely identify the QBU in order to keep track of
the QBU from tax year to tax year. The reference ID
number must meet the requirements set forth above.

Line 1f—Effective date as a section 987 QBU. Enter
the date on which the QBU became a section 987 QBU
(for example, the date on which the QBU adopted a
functional currency that is different from its owner, or the
QBU was acquired by an owner that has a different
functional currency).
If the owner has made a section 987 QBU grouping
election under Regulations section 1.987-1(b)(3)(ii), then
enter the effective date of the election. If the section 987
QBU is a combined or separated QBU, enter the date on
which the combination or separation occurred.
If the section 987 QBU is a successor deferral QBU or
successor suspended loss QBU, enter the date of the
deferral event as described in Regulations section
1.987-12(g)(1) or the date of the QBU termination
described in Regulations section 1.987-13(b) or (c).
Line 1g. Enter on line 1g the two letter country codes
(from the list at IRS.gov/CountryCodes).
Line 1h. Enter on line 1h the six-digit code selected from
the list at the end of the instructions for Form 1120.
Line 1i. Enter a brief description of the company’s
business activity.
Line 1j—Functional currency of QBU. The functional
currency of the section 987 QBU is determined under
section 985. Enter the applicable three-character alphabet
code for the QBU's functional currency using the ISO
4217 standard. These codes are available at sixgroup.com/en/products-services/financial-information/
data-standards.html#scrollTo=currency-codes. Click on
List One (XLS).
Line 2—QBU’s U.S. office or agent. Enter the name
and identifying number of the QBU’s office or agent
located in the United States (if different from the
authorized person or the QBU’s owner).
The identifying number is the EIN if the agent or office
is a legal entity. Otherwise, enter the EIN of the agent or
office’s owner. If the agent is a domestic corporation that
is a member of a consolidated group, list the common
parent’s EIN on line 2b(1). Filers are permitted to enter
both an EIN on line 2b(1) and a reference ID number on

6

Part II—Listing of QBUs for
Authorized Persons With Multiple
Owners and/or Multiple QBUs

Authorized persons making section 987 elections for
multiple QBU owners and/or with respect to multiple
section 987 QBUs must use Part II, Sections A and B to
provide information for each QBU owner and section 987
QBU subject to the section 987 elections. Attach
statement where necessary to furnish information.

Section A—Information of QBUs Subject to the
Consistency Requirements of Regulations
Section 1.987-1(g)(2)
If the authorized person makes section 987 elections for
an owner with multiple section 987 QBUs or for multiple
owners that are subject to the consistency rules of
Regulations section 1.987-1(g)(2), complete Section A
and attach statements where necessary.

Line 1. If the authorized person is a U.S. person (other
than a partnership) or a domestic partnership, check “Yes”
in the appropriate line and attach a statement listing all
section 987 QBUs owned by the authorized person.
Line 2. If the authorized person owns (directly or
indirectly, by vote or value) more than 50% of the stock of
one or more CFCs that own a section 987 QBU, attach a
statement listing all section 987 QBUs owned by the
CFC(s).
Line 3. If the authorized person owns (directly or
indirectly) more than 50% of the capital and profits
interests in one or more foreign partnerships, which in turn
own one or more section 987 QBUs, attach a statement
listing all section 987 QBUs owned by the foreign
partnerships.

Section B—–Information of QBUs Not Subject to
the Consistency Requirements of Regulations
Section 1.987-1(g)(2)
Line 1. Attach a statement listing all QBU owners and
section 987 QBUs for which the authorized person is
making or revoking the section 987 elections, other than
the QBU owners and section 987 QBUs listed in
Section A.

Part III—Type of Election

In general, a section 987 election may not be made or
revoked without the consent of the Commissioner, except
for initial year elections and certain elections eligible to be
made or revoked without the consent requirement. See
When and Where To File, earlier.
An authorized person who files Form 8964-ELE in
accordance with these instructions is deemed to satisfy

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Lines 1d and 1e—QBU country, entity type, and date
of organization. Enter on line 1d the country of formation
using the two letter country codes (from the list at IRS.gov/
CountryCodes), and the legal form of the QBU’s
organization. A QBU may be a legal entity disregarded for
U.S. tax purposes or a branch of its owner. Provide the full
legal designation of the QBU if it is a legal entity.
Otherwise, enter “branch.”
Enter on line 1e the date of the QBU’s organization (if it
is a legal entity) or the date on which the section 987
QBU’s trade or business was established.

line 2b(2). The reference ID number must meet the
requirements set forth above.
Line 2(d)—Name and address of person(s) with
custody of QBU books and records. Enter the name
and address (including corporate department, if
applicable) of person(s) with custody of the books and
records of the QBU and, if different, the location of the
books and records.

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the requirement to file a statement described in
Regulations section 1.987-1(g)(3)(i).
Check the box corresponding to the election(s) you
wish to make or revoke. In addition, check the box next to
any election that was made in a previous year and
continues to be in effect.
For each election that is being made or revoked,
provide the EIN of the authorized person that is making or
revoking the election. For each election that was made in
a previous year and continues to be in effect, provide the
EIN of the authorized person that made the original
election.
The effective date of an election is the first day of the
first tax year to which the election applies under
Regulations section 1.987-1(g). The effective date of a
revocation of an election is the first day of the first tax year
in which the election ceases to apply.

Line 1—Name and telephone number of the representative of authorized person. Enter the name, title,
and phone number of the authorized person’s
representative with power of attorney to respond to IRS
inquiries. See Form 2848, Power of Attorney and
Declaration of Representative, available at IRS.gov/
Form2848.
Line 2. If the authorized person is making an election for
a CFC, provide the name, EIN, and the percentage of
voting stock of the CFC’s controlling domestic
shareholder(s) determined under Regulations section
1.964-1(c)(5)(i). Attach statement if additional space is
required.
Note: If the name of the authorized person, CFCs, or
controlling domestic shareholders filing the return whose
activities are being reported changed within the past 3
years, show the prior name(s) in parentheses after the
current name.

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Line 5—Election to use Spot Rate Convention. If you
are making an election to use a spot rate convention,
attach a statement describing the spot rate convention.

Part IV—Other Information

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Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the
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and to allow us to figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act
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The estimated burden for taxpayers filing this form is approved under OMB control number 1545-0123.

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If you have comments concerning the accuracy of these time estimates or suggestions for making this form and
related schedule simpler, we would be happy to hear from you. You can send us comments through IRS.gov/
FormComments. Or, you can write to the Internal Revenue Service, Tax Forms and Publications Division, 1111
Constitution Ave. NW, IR-6526, Washington, DC 20224. Do not send the tax form to this address. Instead, see Where To
File, earlier, near the beginning of the instructions.

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