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Official form guide
Form 8964-ELE: Section 987 Elections
IRS Form 8964-ELE is used to make or revoke Section 987 elections and must be attached to the original, timely filed (including extensions) return for the tax year of the election. The authorized person for a QBU files it.
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IRS Form 8964-ELE - Section 987 Elections
IRS Form 8964-ELE is used to make or revoke Section 987 elections and must be attached to the original, timely filed (including extensions) return for the tax year of the election. The authorized person for a QBU files it.
Risk Radar
Scan points- 1Fail to attach Form 8964-ELE to the original timely filed return.
- 2Entering “See attached” in a section instead of completing all entry spaces.
- 3Not attaching required statements for foreign partnerships that own more than 50% of a QBU.
- 4Failing to check “Yes” for multiple owners/QBUs when applicable, leading to incomplete Part II.
- 5Omitting the authorized person’s name or identifying number on the form.
Plain English
Form 8964-ELE lets the authorized person tell the IRS how a foreign qualified business unit will treat currency gains or losses. It records the owner’s details and election choice. The completed form is sent together with the tax return for that year.
Submission Date
- Filing date: 2026-01-12 10:10:44
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when making or revoking a section 987 election for a qualified business unit.
- Check Form 2848 instead when you need to file a power of attorney for the authorized person’s representative.
Form selector
Use this form or another form?
Granting a representative power of attorney to respond to IRS inquiries
Required to authorize the representative under the power of attorney rules
✓ Verify the representative’s POA before filing
Changing the authorized person’s representative after filing the election
Needed to update the power of attorney for the new representative
✓ Ensure the new POA is signed and attached
Providing a power of attorney for a foreign partnership owner involved in the election
Used to allow the partner’s agent to act on the partnership’s behalf
✓ Confirm the agent’s authority is correctly documented
Deadline or filing window
The filing deadline matches the due date of the tax return for the year of the election. If the taxpayer files an extension for the return, the form may be submitted by that extended deadline. No separate deadline is provided.
Checklist
What you need before filling it out
Annual Accounting Period
Title of Form 8964-ELE and accounting period · Form header section
Name and identifying number of the filer
Filer’s name and EIN or reference ID · Identifying Information section
Statement of QBUs owned by foreign partnerships
List of QBUs attached to the form · Attachment for foreign partnership ownership
Spot rate convention election description
Written description of the spot rate convention · Attachment for spot rate convention
Representative’s name, title, and phone number
Representative’s contact information · Part IV, Line 1
Before you submit
- 1Confirm the form title reads "Section 987 Elections"
- 2Verify the annual accounting period matches the tax year of the election
- 3Enter the authorized person’s name and identifying number accurately
- 4Attach any required statements for foreign partnership owned QBUs
- 5Attach a spot rate convention description if making that election
- 6Ensure any power of attorney representative information includes a completed Form 2848
- 7Sign the form where required
How to file this form
- 1Enter the form title and annual accounting period on the Identifying Information section and retain proof of the entered period
- 2Provide the authorized person’s name and identifying number, then keep a copy of the completed identification block
- 3Attach all required statements (QBU list, spot rate convention, etc.) and file the attachments with the form
- 4Sign the form as the authorized person and retain the signed copy for records
- 5Attach Form 8964-ELE to the original, timely filed (including extensions) return for the tax year of the election and keep a filing receipt
Known limitations
- 1Computer-generated Form 8964-ELE requires prior IRS approval unless it exactly conforms to the official form and schedules. (Instructions p.4)
- 2If required information exceeds the space in a section, you may not write “See attached”; instead complete all entry spaces and attach additional sheets that conform to the IRS version. (Instructions p.5)
- 3When the authorized person represents multiple QBU owners or an owner with multiple QBUs, they must check “Yes” and complete only Part II; otherwise they must check “No” and complete only Part I. (Instructions p.5)
- 4Form 8964-ELE must be attached to the original, timely filed (including extensions) return for the tax year of the election; it cannot be filed separately. (Instructions p.1)
Field map
Compact field-by-field guide
Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
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Fillable formOpen in Editor->Form 8964-ELE is the December 2025 revision; the instructions point to IRS.gov/Form8964ELE for the latest information.
What changed or needs a fresh check
- Edition date — confirm the revision reads December 2025
- Fee — Not stated in the official source
- Mailing address — Not stated in the official source
- Signature — Not stated in the official source
- Authorized person identification — confirm name and identifying number are entered as required
Quick Facts
Downloads
Sources
- SRCInstructions p.1 — Form 8964-ELE must be attached to the original, timely filed (including extensions) return for the tax year.
- SRCInstructions p.4 — Computer-generated Form 8964-ELE requires prior IRS approval unless it conforms exactly to the official form and schedules.
- SRCInstructions p.4 — If a computer-generated Form 8964-ELE conforms, it may be filed without prior approval, but attach the approval letter.
- SRCInstructions p.5 — Do not enter “See attached” when information exceeds space; attach additional sheets that conform to the IRS version.
- SRCInstructions p.5 — For multiple QBU owners or QBUs, check “Yes” and complete only Part II; otherwise check “No” and complete only Part I.
- SRCInstructions p.1 — The authorized person files Form 8964-ELE for the owner of a section 987 QBU.
- SRCInstructions p.1 — Section 987 applies to any taxpayer that has a qualified business unit with a functional currency other than the dollar.
- SRCInstructions p.1 — Section 987 regulations provide rules for calculating foreign currency gain or loss under section 987(3).
Common confusion points
Do I need IRS approval for a computer-generated Form 8964-ELE?
Because the instructions differentiate between approved and conforming forms.
→ Verify that the form exactly matches the official layout and, if required, attach the approval letter.
Can I write “See attached” if a section runs out of space?
The instructions explicitly forbid that wording.
→ Ensure all entry spaces are filled and attach additional sheets that follow the IRS version.
Do I file Form 8964-ELE separately or attach it to my return?
Filing instructions state it must be attached to the original return.
→ Attach Form 8964-ELE to the original, timely filed return for the tax year.
What if I am the authorized person for multiple QBU owners?
The form has a specific part selection rule for multiple owners.
→ Check “Yes” and complete only Part II.
What if I am the authorized person for a single QBU?
The form requires a different part selection for a single owner.
→ Check “No” and complete only Part I.
Do I need to attach the approval letter when filing?
The exception note mentions attaching the approval letter if prior approval was obtained.
→ Attach the approval letter to Form 8964-ELE when using a computer-generated version that required approval.
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- Form 1120X – amended corporate return to correct a section 987 election.
Questions about IRS Form 8964-ELE
What is IRS Form 8964-ELE used for?
Form 8964-ELE lets the authorized person tell the IRS how a foreign qualified business unit will treat currency gains or losses. It records the owner’s details and election choice. The completed form is sent together with the tax return for that year.
Who must file IRS Form 8964-ELE?
The authorized person of a Section 987 qualified business unit owner must file IRS Form 8964-ELE.
What information does IRS Form 8964-ELE require?
The form gathers the QBU owner’s name, identifying number, annual accounting period, and whether the filer has multiple owners or QBUs, using Part I or Part II as appropriate.
When is IRS Form 8964-ELE due?
It is due when the original return for the tax year is filed, and extensions are allowed if the return is extended.
Where do I file IRS Form 8964-ELE?
Attach Form 8964-ELE to the original tax return; do not mail it separately.
How do I complete IRS Form 8964-ELE?
Enter the authorized person’s name and identifying number, then answer whether there are multiple owners or QBUs. Complete Part I if No, or Part II if Yes, providing all required lines. Do not write “See attached” in any section; attach additional sheets that follow the IRS format for any overflow. Finally, attach the completed form to the original timely‑filed return.
Do I need IRS approval for a computer-generated Form 8964-ELE?
Because the instructions differentiate between approved and conforming forms. Verify that the form exactly matches the official layout and, if required, attach the approval letter.
Can I write “See attached” if a section runs out of space?
The instructions explicitly forbid that wording. Ensure all entry spaces are filled and attach additional sheets that follow the IRS version.
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