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Section 988.–Treatment of Certain Foreign Currency Transactions

An instrument that requires payments to be made in a foreign currency (that is, nonfunctional currency) can be debt for U.S. federal income tax purposes.

Click here to view / download IRS PDF Section 988.–Treatment of Certain Foreign Currency Transactions 

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Currency exchange rates

The Internal Revenue Service has no official exchange rate. Generally, it accepts any posted exchange rate that is used consistently.

When valuing currency of a foreign country that uses multiple exchange rates, use the rate that applies to your specific facts and circumstances.

Note: The exchange rates referenced on this page do not apply when making payments of U.S. taxes to the IRS.  If the IRS receives U.S. tax payments in a foreign currency, the exchange rate used by the IRS to convert the foreign currency into U.S. dollars is based on the date the foreign currency is converted to U.S. dollars by the bank processing the payment, not the date the foreign currency payment is received by the IRS.