# [Amended]
**AGENCY:**
Internal Revenue Service (IRS), Treasury.
**ACTION:**
Final rule; correction and correcting amendments.
**SUMMARY:**
This document includes corrections to a final regulation (Treasury Decision 10016) published in the *Federal Register* on Wednesday, December 11, 2024. Treasury Decision 10016 contained final regulations relating to the determination of taxable income or loss and foreign currency gain or loss with the respect to a qualified business unit.
**DATES:**
These corrections are effective on January 17, 2025. For dates of applicability, see § 1.987-15.
**FOR FURTHER INFORMATION CONTACT:**
Concerning the final regulations generally, Adam G. Province at (865) 329-4546; concerning the character and source of section 987 gain or loss, Larry Pounders at (202) 317-5465; concerning consolidated groups, Jeremy Aron-Dine at (202) 317-6847 (not toll-free numbers).
**SUPPLEMENTARY INFORMATION:**
**Background**
The final regulations (TD 10016) that are the subject of this correction are under sections 861, 985 through 989, and 1502 of the Internal Revenue Code.
**Corrections to Publication**
Accordingly, FR Doc. 2024-28372 (TD 10016) appearing on page 100138 in the *Federal Register* on Wednesday, December 11, 2024, is corrected as follows:
1. On page 100155, in the third column, under the caption “A. Loss Suspension Rule 1. In General”, the second line of the third full paragraph is corrected to read “proposed § 1.987-11(c)”.
**List of Subjects in 26 CFR Part 1**
Income taxes, Reporting and recordkeeping requirements.
**Correction to the Regulations**
Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:
**PART 1—INCOME TAXES**
**26 CFR Part 1**
*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:
**Authority:**
26 U.S.C. 7805 * * *
**26 CFR Part 1**
*Par. 2.* Section 1.987-1 is amended by revising the first sentence of paragraph (b)(3)(ii)(A) to read as follows:
§ 1.987-1
(b) * * *
(3) * * *
(ii) * * *
(A) * * * Solely for purposes of section 987, an owner may elect to treat all section 987 QBUs with the same functional currency as a single section 987 QBU except to the extent provided in paragraph (b)(3)(ii)(B) of this section. * * *
**26 CFR Part 1**
*Par. 3.* Section 1.987-2 is amended by revising the second sentence of paragraph (c)(10)(xviii)(B)( *2* ) to read as follows:
§ 1.987-2
(c) * * *
(10) * * *
(xviii) * * *
(B) * * *
( *2* ) * * * Under § 1.987-5(c)(4) and § 1.987-8(e), a termination of a section 987 QBU is treated as a remittance of all the gross assets of the section 987 QBU to the owner on the date of the termination. * * *
**26 CFR Part 1**
§ 1.1502-13
*Par. 4.* Section 1.1502-13 is amended by redesignating the second occurrence of paragraph (j)(10)(vi) as (j)(10)(vii).
Regina L. Johnson,
Federal Register Liaison, Publications and Regulations Section, Associate Chief Counsel (Procedure and Administration).