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Section 987 Equity and Basis Pool Method Calculator

2026-04-07

Section 987

In February 2026, the IRS published Notice 2026-17. This notice announced new rules that permit taxpayers to determine taxable income or loss and foreign currency gain or loss with respect to a qualified business unit (QBU) using a method that is substantially similar to the method provided in regulations proposed in 1991.

This new method, the equity and basis pool method, is dramatically less complicated than the method provided in the final Section 987 regulations. The equity and basis pool method is a welcome relief, especially for small businesses with QBUs.

We have created a web page that performs the Section 987 calculations under Notice 2026-17.

Tags: 987 Branch Transactions