On 13 May 2019, Treasury Decision (TD) 9857 was published in the federal register, which contains final regulations relating to combinations and separations of qualified business units (QBUs) subject to section 987 and the recognition and deferral of foreign currency gain or loss with respect to a QBU subject to section 987 in connection with certain QBU terminations and certain other transactions involving partnerships. TD 9857 also withdraws temporary regulations regarding the allocation o…