SECTION 29. FUNCTIONAL

CURRENCY (§ 985)

.01 Change in functional currency . (1) Description of change . This change applies to a taxpayer that wants to change its functional currency or the functional currency of a qualified business unit (QBU) of the taxpayer. The preceding sentence does not apply to a QBU of a taxpayer described in § 1.985–1(b)(1)(iii).

(2) Manner of making change . A taxpayer making this change must make all necessary adjustments required by such change. See §§ 1.985–5, 1.985–8(c). A taxpayer must attach a statement to the Form 3115 representing that it has made the adjustments set forth in § 1.985–5 or § 1.985–8(c). The statement must also provide the amount of any unrealized exchange gain or loss required to be taken into account pursuant to § 1.985–5 or § 1.985–8(c) and the date on which a taxpayer took such amount into account. Finally, the statement must provide a detailed and complete description of any other adjustments required pursuant to § 1.985–5 or § 1.985–8(c).

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 29.01 is “70.” (4) Contact information . For further information regarding a change under this section, contact Peter Merkel at (202) 317-4919 (not a toll-free number). .02 Reserved .

Bulletin No. 2015–5 553 February 2, 2015