Form 8964-TRA — Section 987 Transition Information

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/f8964tra.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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(December 2025)

Department of the Treasury Internal Revenue Service

See instructions for a list of products to which Form 8964-TRA can be attached.

Go to www.irs.gov/form8964tra for instructions and the latest information. OMB No. 1545-0123

Information furnished for qualified business unit’s tax year beginning , 20 , ending , 20

Name of filer Filer’s identifying number

Name of QBU Identifying number Reference ID number

Part I Section 987 Transition Information

Provide a description of the prior method used by the taxpayer to determine its section 987 gain or (loss), deferred section 987 gain or (loss), or outbound section 987 (loss) with respect to the section 987 QBU including an explanation as to whether such method was an eligible pretransition method as defined in Regulations section 1.987-10(e)(4). Attach a statement if additional space is needed.

Check applicable box: Owner of a Section 987 QBU Deferral QBU Owner

Owner of an Outbound Loss QBU Owner of a Terminating QBU

Enter the applicable transition date pursuant to Regulations section 1.987-10(c) . . . . . . . . . . . . / /

Enter the applicable transition exchange rate pursuant to Regulations section 1.987-10(d)(3) . . . . . . . .

Enter the applicable pretransition translation rate pursuant to Regulations section 1.987-10(e)(2)(i)(C) . . . . . .