Form 8964-ELE — Section 987 Elections

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/f8964ele.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

---

Form

Go to www.irs.gov/form8964ele for instructions and the latest information. OMB No. 1545-0123

Department of the Treasury Internal Revenue Service

Internal Revenue Service For tax year beginning , 20 , and ending , 20 .

Name of filer Filer’s identifying number

Name of authorized person Identifying number Reference ID number (see instructions)

Number and street (or P.O. box number if mail is not delivered to street address) Room or suite no. City or town State or province ZIP or foreign postal code

Does the authorized person have multiple owners and/or multiple QBUs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No If “Yes,” skip Part I and complete Part II. If “No,” complete Part I and skip Part II.

Part I Identifying Information of Owner and QBU Section A—Owner information

1 For the owner of the QBU, if different than the authorized person, provide the following (see instructions). a Name b Annual accounting period and tax year of the owner when

election or revocation is made (see instructions)

c Address d(1) Identifying number, if any

d(2) Reference ID number (see instructions)

e Name and address (including corporate department, if applicable) of person(s) with custody of the books and records of the QBUs

f Country under whose laws organized

g Functional currency

2 For the direct owner of the QBU (if different from the owner), provide the following (see instructions). a Name b Country under whose laws organized

c Address d Functional currency

Section B—QBU information

1 Provide the following information for the QBU subject to elections. a Name of QBU b(1) Identifying number, if any

c Address of QBU b(2) Reference ID number (see instructions)

d For QBU, country(ies) under whose laws organized and entity type under local tax law e Date(s) of organization f Effective date as QBU

g Country(ies) in which principal business activity is conducted h Principal business activity code number

i Principal business activity j Functional currency

For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 95655D Form 8964-ELE (12-2025) Created 12/4/25

Form 8964-ELE (12-2025) Page 2 Part I Identifying Information of Owner and QBU (continued) Section B—QBU information (continued)

2 Provide the following information for the owner’s accounting period stated above. a Name of QBU office or agent (if any) in the United States b(1) Identifying number

c Address b(2) Reference ID number

d Name and address (including corporate department, if applicable) of person(s) with custody of the books and records of the QBU, and the location of such books and records, if different

Part II Listing of QBUs for Authorized Persons With Multiple Owners and/or Multiple QBUs Complete Sections A and B and attach statements for authorized persons with multiple owners and QBUs. See instructions. Section A—QBU information. For authorized persons with multiple QBUs subject to the consistency rules in Regulations section 1.987-1(g)(2).

See instructions.

1a Is the authorized person a U.S. person other than a partnership? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No If “Yes,” list the QBUs owned by the authorized person. Attach statement. b Is the authorized person a domestic partnership? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No If “Yes,” list the QBUs owned by the authorized person. Attach statement.

2 List the QBUs of Controlled Foreign Corporations (CFCs) that are required to make elections consistently with the authorized person under Regulations section 1.987-1(g)(2)(ii). Attach statement. 3 List the QBUs of foreign partnerships that are required to make elections consistently with the authorized person under Regulations section 1.987-1(g)(2)(ii). Attach statement. 4 Other information. Attach statement. Section B—QBU information. For authorized persons with multiple QBUs not subject to the consistency rules in Regulations section 1.987-1(g)(2).

See instructions.

1 List any QBUs not listed in Section A for which the authorized person is making the elections in Part III. Attach statement. 2 Other information. Attach statement.

Form 8964-ELE (12-2025) Page 3 Part IV Other Information 1 Name and title of the representative of authorized person making election whom the IRS may call for more information Representative’s telephone number

2 For CFCs listed in Part I, Section A, Line 1, or Part II, Section A, Line 2, list Controlling Domestic Shareholders and EIN.

(a) Name of CFC (b) Identifying

number

(c) Reference ID (d) Name of U.S. Shareholder (e) TIN of U.S.

Shareholder

(f) Percent of

voting stock

a b c d e

Form 8964-ELE (12-2025)