The U.S. IRS has released an international practice unit, Overview of IRC 987 and Branch Operations in a Foreign Currency. The general overview of the practice unit includes the following:
In a global economy, many U.S. Corporations ("USC") are doing business through foreign branches, divisions or disregarded entities that operate in currencies other than the U.S. dollar. The U.S. federal income tax system for U.S. owned Multinational Enterprises ("US MNE") is based on worldwide income in U…