Modifications to Rules for Computing Taxable Income or Loss and Foreign Currency Gain or Loss Under Section 987 (Notice 2026-17)

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations (forthcoming proposed regulations) under section 987. The Treasury Department and IRS expect the forthcoming proposed regulations to include proposed rules that are consistent with the rules described in sections 3 through 5 of this notice.