)
or https:// means you've safely connected to the .gov website. Share sensitive information only on official, secure websites.
On August 14, 2026, the Treasury Department and the IRS issued proposed regulations under section 987 (REG-103844-26). that provide rules relating to the CFC exemption election. A CFC that is subject to a CFC exemption election is referred to as an “exempt CFC.” Taxpayers are permitted to rely on the rules of the proposed regulations to the extent provided in the preamble to the proposed regulations.
The following instructions apply when an exempt CFC is deemed to have no pretransition gain or loss with respect to a QBU under Proposed Regulations section 1.987-15(d)(2). In Part I of Form 8964-TRA, state that the QBU is deemed to have no pretransition gain or loss under Proposed Regulations section 1.987-15(d)(2) and report the amount of the QBU’s assets described in Proposed Regulations section 1.987-15(e)(2)(iii)(B). Do not complete Parts II and III of Form 8964-TRA with respect to the QBU.