8964-ELE Section 987 Elections

Note: The draft you are looking for begins on the next page.

Caution: DRAFT—NOT FOR FILING

This is an early release draft of an IRS tax form, instructions, or publication,
which the IRS is providing for your information. Do not file draft forms. We
incorporate all significant changes to forms posted with this coversheet.
However, unexpected issues occasionally arise, or legislation is passed—in this
case, we will post a new draft of the form to alert users that changes were made
to the previously posted draft. Thus, there are never any changes to the last
posted draft of a form and the final revision of the form. Forms and instructions
are subject to OMB approval before they can be officially released, so we post
drafts of them until they are approved. Drafts of instructions and pubs usually
have some additional changes before their final release. Early release drafts are
at IRS.gov/DraftForms and remain there after the final release is posted at
IRS.gov/LatestForms. Also see IRS.gov/Forms.
Most forms and publications have a page on IRS.gov: IRS.gov/Form1040 for
Form 1040; IRS.gov/Pub501 for Pub. 501; IRS.gov/W4 for Form W-4; and
IRS.gov/ScheduleA for Schedule A (Form 1040), for example, and similarly for
other forms, pubs, and schedules for Form 1040. When typing in a link, type it
into the address bar of your browser, not a Search box on IRS.gov.
If you wish, you can submit comments to the IRS about draft or final forms,
instructions, or pubs at IRS.gov/FormsComments. Include “NTF” followed by the
form or pub number (for example, “NTF1040”, “NTFW4”, “NTF501”, etc.) in the
body of the message to route your message properly. We cannot respond to all
comments due to the high volume we receive and may not be able to consider
many suggestions until the subsequent revision of the product, but we will
review each “NTF” message. If you have comments on reducing paperwork and
respondent (filer) burden, with respect to draft or final forms, please respond to
the relevant information collection through the Federal Register process; for
more info, click here.

TREASURY/IRS AND OMB USE ONLY DRAFT

8964-ELE

Form
(December 2025)

Department of the Treasury
Internal Revenue Service
Name of filer

Section 987 Elections
OMB No. 1545-0123

Go to www.irs.gov/form8964ele for instructions and the latest information.
, 20

For tax year beginning

Filer’s identifying number
Identifying number

Name of authorized person
Number and street (or P.O. box number if mail is not delivered to street address)

.

, 20

, and ending

Room or suite no.

Does the authorized person have multiple owners and/or multiple QBUs?
If “Yes,” skip Part I and complete Part II.
If “No,” complete Part I and skip Part II.

.

.

.

.

Reference ID number (see instructions)

City or town

.

.

.

.

State or province

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

ZIP or foreign postal code

.

.

.

.

.

.

.

Yes

No

Part I
Identifying Information of Owner and QBU
Section A—Owner information
a

For the owner of the QBU, if different than the authorized person, provide the following (see instructions).
Name

c

Address

b Annual accounting period and tax year of the owner when
election or revocation is made (see instructions)
d(1) Identifying number, if any
d(2) Reference ID number (see instructions)

e

Name and address (including corporate department, if applicable) of person(s) with custody of the books and
records of the QBUs

f Country under whose laws organized
g Functional currency

2
a

For the direct owner of the QBU (if different from the owner), provide the following (see instructions).
Name

b Country under whose laws organized

c

Address

d Functional currency

Section B—QBU information
1
a

Provide the following information for the QBU subject to elections.
Name of QBU

b(1) Identifying number, if any

c

Address of QBU

b(2) Reference ID number (see instructions)

d

For QBU, country(ies) under whose laws organized and entity type under local tax law

e Date(s) of organization

g

Country(ies) in which principal business activity is conducted

h Principal business activity code number

i

Principal business activity

j Functional currency

For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 95655D

f Effective date as QBU

Form 8964-ELE (12-2025) Created 12/4/25

DRAFT — DO NOT FILE

DRAFT — DO NOT FILE

1

TREASURY/IRS AND OMB USE ONLY DRAFT
Page 2

Form 8964-ELE (12-2025)

Part I
Identifying Information of Owner and QBU (continued)
Section B—QBU information (continued)
2
a

Provide the following information for the owner’s accounting period stated above.
Name of QBU office or agent (if any) in the United States

b(1) Identifying number

c

Address

b(2) Reference ID number

d

Name and address (including corporate department, if applicable) of person(s) with custody of the books and records of the QBU, and the location of such books and records, if
different

Listing of QBUs for Authorized Persons With Multiple Owners and/or Multiple QBUs
Complete Sections A and B and attach statements for authorized persons with multiple owners and QBUs. See instructions.
Section A—QBU information. For authorized persons with multiple QBUs subject to the consistency rules in Regulations section 1.987-1(g)(2).
See instructions.
1a
b
2
3
4

Is the authorized person a U.S. person other than a partnership? . . . .
If “Yes,” list the QBUs owned by the authorized person. Attach statement.
Is the authorized person a domestic partnership?
. . . . . . . .
If “Yes,” list the QBUs owned by the authorized person. Attach statement.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

Yes

No

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

Yes

No

List the QBUs of Controlled Foreign Corporations (CFCs) that are required to make elections consistently with the authorized person under Regulations section 1.987-1(g)(2)(ii). Attach
statement.
List the QBUs of foreign partnerships that are required to make elections consistently with the authorized person under Regulations section 1.987-1(g)(2)(ii). Attach statement.
Other information. Attach statement.

Section B—QBU information. For authorized persons with multiple QBUs not subject to the consistency rules in Regulations section 1.987-1(g)(2).
See instructions.
1
2

List any QBUs not listed in Section A for which the authorized person is making the elections in Part III. Attach statement.
Other information. Attach statement.

Part III

Type of Election (see instructions)
Identifying
number

1
2
3
4
5
6
7
8

Section 987 Current Rate Election—Regulations section 1.987-1(d)(2) . . . . . .
Section 987 Annual Recognition Election—Regulations section 1.987-5(b)(2) . . . .
Section 988 Mark-to-Market Election—Regulations section 1.987-3(b)(4)(ii) . . . .
Section 987 Grouping Election—Regulations section 1.987-1(b)(3)(ii) . . . . . .
Election To Use a Spot Rate Convention—Regulations section 1.987-1(c)(1)(ii) . . .
Election To Use the Historic Inventory Method—Regulations section 1.987-3(c)(2)(iv)(B)
Amortization Election in the Transition Rules—Regulations section 1.987-10(e)(5)(ii)(A) .
Small Business Election in the Transition Rules—Regulations section 1.987-10(e)(7)(iv) .

9

Election To Characterize Certain Section 987 Gain/(Loss) as Foreign Currency Gain/(Loss) From Section 988
Transactions—Regulations section 1.987-6(b)(2)(i)(C)(1) . . . . . . . . . . . . . . . . . . . .

10

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

.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

.
.
.
.
.
.
.
.

.

Effective date
of the election

Effective date
of the revocation

.
.
.
.
.
.
.
.

.
Form 8964-ELE (12-2025)

DRAFT — DO NOT FILE

DRAFT — DO NOT FILE

Part II

TREASURY/IRS AND OMB USE ONLY DRAFT
Page 3

Form 8964-ELE (12-2025)

Part IV

Other Information

1

Name and title of the representative of authorized person making election whom the IRS may call for more information

2

For CFCs listed in Part I, Section A, Line 1, or Part II, Section A, Line 2, list Controlling Domestic Shareholders and EIN.
(a) Name of CFC

(b) Identifying
number

(c) Reference ID

(d) Name of U.S. Shareholder

Representative’s telephone number

(e) TIN of U.S.
Shareholder

(f) Percent of
voting stock

a
b
c
d
e

DRAFT — DO NOT FILE

DRAFT — DO NOT FILE

Form 8964-ELE (12-2025)