26 CFR § 1.987-6T - Character and source of section 987 gain or loss (temporary).
---
identifier: "/us/cfr/t26/s1.987-6T"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 1.987-6T - Character and source of section 987 gain or loss (temporary)."
title_number: 26
title_name: "Internal Revenue"
section_number: "1.987-6T"
section_name: "Character and source of section 987 gain or loss (temporary)."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "A"
subchapter_name: "INCOME TAX"
part_number: "1"
part_name: "INCOME TAXES"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805, unless otherwise noted."
regulatory_source: "T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 21, 1960; T.D. 9989, 89 FR 17606, Mar. 11, 2024, unless otherwise noted."
cfr_part: "1"
---
# 1.987-6T Character and source of section 987 gain or loss (temporary).
(a) through (b)(3) [Reserved] For further guidance, see § 1.987-6(a) through (b)(3).
(4) *Source of section 987 gain or loss with respect to a dollar QBU.* The source of section 987 gain or loss with respect to a dollar QBU (as defined in § 1.987-1T(b)(6)(i)) for which the CFC owner has elected under § 1.987-1T(b)(6)(iii) to apply section 987 is determined by reference to the residence of the CFC owner. This paragraph (b)(4) applies to any CFC that has made the election under § 1.987-1T(b)(6)(iii), including a CFC described in § 1.987-1(b)(1)(ii).
(c) [Reserved] For further guidance, see § 1.987-6(c).
(d) *Effective/applicability date.* This section applies to taxable years beginning on or after one year after the first day of the first taxable year following December 7, 2016. Notwithstanding the preceding sentence, if a taxpayer makes an election under § 1.987-11(b), then this section applies to taxable years to which §§ 1.987-1 through 1.987-10 apply as a result of such election.
(e) *Expiration date.* The applicability of this section expires on December 6, 2019.
[T.D. 9795, 81 FR 88874, Dec. 8, 2016]