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Form 8964-ELE: Section 987 Elections
IRS Form 8964-ELE is used to make or revoke elections under section 987 regulations for an owner of a section 987 QBU. The form satisfies the reporting requirements of Regulation section 1.987-1(g).
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IRS Form 8964-ELE - Section 987 Elections
IRS Form 8964-ELE is used to make or revoke elections under section 987 regulations for an owner of a section 987 QBU. The form satisfies the reporting requirements of Regulation section 1.987-1(g).
Risk Radar
Scan points- 1If you have multiple entities, ensure you use Part II instead of skipping directly to Part III.
- 2Failing to complete Part II when making elections for multiple QBUs or owners.
- 3Entering 'See attached' in a section instead of completing all entry spaces first.
- 4Not providing the annual accounting period title on Form 8964-ELE itself.
- 5Omitting the QBU owner's identifying number on Line 1b (Part I).
Plain English
This form allows you to officially declare (make) or cancel (revoke) certain tax elections related to foreign currency gain or loss under Section 987. It is necessary when property transfers occur between Qualified Business Units (QBUs) that use different functional currencies.
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 an owner of a section 987 QBU needs to make or revoke elections under the section 987 regulations.
- Do not use it when the taxpayer does not own a qualified business unit with a functional currency other than the dollar (QBU).
- Check Form 2848 instead when an authorized person needs to provide a Power of Attorney and Declaration of Representative.
Form selector
Use this form or another form?
Filing for a CFC election
Required if the QBU is part of a Controlled Foreign Corporation (CFC).
✓ Check Part IV, Line 2.
Foreign partnership owns QBUs
Required if the authorized person owns more than 50% of capital/profits interests in foreign partnerships that own section 987 QBUs.
✓ Check instructions for attaching statement (p.6).
Election to characterize passive gain/loss
Necessary when making an election to treat passive category QBU gain or loss as a foreign currency gain or loss from section 988 transactions for subpart F purposes.
✓ Check instructions for Part III.
Making initial year elections
Initial year elections may be made without the Commissioner's consent, which is generally required for other elections.
✓ Check instructions for Part III.
Deadline or filing window
The filing deadline is tied to the tax year's return: the authorized person must attach Form 8964-ELE with its original, timely filed return. This applies even if extensions are used for that tax year.
Checklist
What you need before filling it out
Part I: Name of filer
Filer’s name and identifying number · Form 8964-ELE (p.1)
QBU Owner/Filer Status
Does the authorized person have multiple owners and/or multiple QBUs? (Yes/No) · Form 8964-ELE (p.1)
Section A: QBU Owners/Elections
Statement listing all QBU owners and section 987 QBUs for which the election is made (excluding those in Section B) · Form 8964-ELE (p.6)
Part IV, Line 1: Representative Info
Name, title, and phone number of authorized person’s representative with power of attorney · Form 8964-ELE (p.7)
Part IV, Line 2: CFC Election
Name, EIN, and percentage of voting stock of the CFC's controlling domestic shareholder(s) · Form 8964-ELE (p.7)
Election Type (Part III)
The specific election being made or revoked (e.g., spot rate convention, passive characterization) · Part III of the form
Before you submit
- 1Complete all entry spaces in a section before attaching additional sheets if information exceeds space.
- 2If answering 'Yes' to multiple owners/QBUs, ensure Part I is completed and Part II is filled out.
- 3Verify that the Annual Accounting Period title matches the form 8964-ELE.
- 4Confirm the Name of authorized person and their identifying number are provided in Part I.
- 5If applicable, attach a statement listing all QBUs owned by foreign partnerships (if filer owns >50%).
- 6Ensure that if an election to use a spot rate convention is made, a descriptive statement is attached.
- 7Verify the Name, EIN, and percentage of voting stock are provided for any CFC election in Part IV, Line 2.
How to file this form
- 1Complete Part I by providing your name, identifying number, and confirming if you have multiple owners/QBUs.
- 2If applicable, complete Part II by listing all QBU owners and QBUs not covered in Section A or B.
- 3Fill out Part III to specify the type of election being made or revoked (e.g., characterization, spot rate convention).
- 4Complete Part IV with representative details (Line 1) and any required CFC information (Line 2), attaching statements as needed.
- 5Attach Form 8964-ELE with your original, timely filed tax return for the relevant tax year.
- 6Keep a copy of the completed Form 8964-ELE for your records.
Known limitations
- 1The section 987 election applies to any taxpayer that has a qualified business unit (QBU) with a functional currency other than the dollar.
- 2If a corporation becomes a member of a consolidated group, it is deemed to make or revoke any necessary section 987 election to be consistent with the consolidated group.
- 3If a corporation ceases to be a member of a consolidated group and does not join another group, its section 987 elections are unaffected by its departure from the group.
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->The current edition is dated December 2025, and users should reference IRS.gov/Form8964ELE for the latest information regarding Form 8964-ELE.
What changed or needs a fresh check
- Edition date — confirm December 2025
- IRS Form Number — confirm 8964-ELE
- OMB No. — confirm 1545-0123
- Filing location — confirm attachment with the original, timely filed return (unless specific rules apply)
- Signatures — not explicitly detailed as a required signature field in the excerpts, but implied by filing requirement.
Quick Facts
Downloads
After you file
- 1Keep a copy of the filed Form 8964-ELE.
- 2The election remains in effect until it is formally revoked.
- 3If filing computer-generated Form 8964–ELE, attach the IRS approval letter to the form if prior approval was obtained.
- 4When making or revoking an election for a consolidated group, ensure all members of that group have the same section 987 elections in effect.
Sources
- SRCInstructions p.1 — Form 8964-ELE is used to make or revoke elections under section 987 regulations, satisfying Regulation section 1.987-1(g).
- SRCInstructions p.1 — Section 987 applies to any taxpayer that has a qualified business unit (QBU) with a functional currency other than the dollar.
- SRCInstructions p.1 — The authorized person must attach Form 8964-ELE with its original, timely filed return for the tax year elections are made for.
- SRCInstructions p.5 — When filling out identifying information, enter the annual accounting period of the person furnishing information in the space provided below the title of Form 8964-ELE.
- SRCInstructions p.5 — If you are filing for multiple QBU owners or one owner with multiple section 987 QBUs, check 'Yes' and complete only Part II; otherwise, check 'No' and complete only Part I.
- SRCInstructions p.1 — For a consolidated group, the election is made/revoked by the group and applies to all members, meaning elections are in effect for all members at all times.
Common confusion points
Who makes or revokes the election?
The authorized person (as defined elsewhere) must make or revoke the election for the owner of the section 987 QBU.
→ Check that you are filing as the 'authorized person' for the relevant owner.
What if I am the authorized person, but not the QBU owner?
Complete lines 1a through 1g in Part I only if the authorized person is not the QBU owner (e.g., an authorized U.S. corporation making elections for a CFC that owns the QBU).
→ Verify your role relative to the owner on Form 8964-ELE.
How do I enter multiple QBUs or owners?
Check 'Yes' and complete only Part II if you are the authorized person for multiple QBU owners or an owner with multiple section 987 QBUs. Otherwise, check 'No' and complete only Part I.
→ Confirm whether you need to fill out Part I (Owner/QBU Info) or Part II.
What happens if my answers exceed the space on a form section?
Do not enter 'See attached'; instead, complete all entry spaces in that section and attach the remaining information on additional sheets conforming to the IRS version of that section.
→ Ensure your supporting documentation matches the specific section it relates to.
When must I file this election?
The authorized person must attach Form 8964-ELE with its original, timely filed (including extensions) return for the tax year for which the elections are made.
→ Confirm the filing date aligns with the required tax year submission deadline.
What if my form is computer-generated?
If it conforms to and does not deviate from the official form/schedules, it may be filed without prior approval; however, attach the approval letter if one exists.
→ Check for any deviations between your digital copy and the official IRS version.
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⚠ If something goes wrong
- Comments regarding accuracy or simplicity can be sent via IRS.gov/FormComments.
Questions about IRS Form 8964-ELE
What is IRS Form 8964-ELE used for?
This form allows you to officially declare (make) or cancel (revoke) certain tax elections related to foreign currency gain or loss under Section 987. It is necessary when property transfers occur between Qualified Business Units (QBUs) that use different functional currencies.
Who must file IRS Form 8964-ELE?
An authorized person must make or revoke a section 987 election for an owner of a section 987 QBU.
What information does IRS Form 8964-ELE require?
Part I collects the identifying information of the Owner and QBU, while Part II lists QBUs when the authorized person has multiple owners or multiple QBUs. Part III specifies the Type of Election being made or revoked.
When is IRS Form 8964-ELE due?
The authorized person must attach Form 8964-ELE with its original, timely filed (including extensions) return for the tax year for which the elections are made.
Where do I file IRS Form 8964-ELE?
The form must be attached to the timely filed return. Comments regarding time estimates can be sent via IRS.gov/FormComments or written to the Internal Revenue Service at 1111 Constitution Ave. NW, IR-6526, Washington, DC 20224.
How do I complete IRS Form 8964-ELE?
First, complete Part I by providing Owner and QBU details. If applicable, check the box indicating multiple owners/QBUs and proceed to Part II to list all relevant QBUs. Finally, select and complete Part III to state the specific Type of Election being made or revoked.
What happens if IRS Form 8964-ELE is filed incorrectly?
The source does not specify a penalty for incorrect filing but requires timely attachment to the return; failure implies non-compliance with reporting requirements.
Who makes or revokes the election?
The authorized person (as defined elsewhere) must make or revoke the election for the owner of the section 987 QBU. Check that you are filing as the 'authorized person' for the relevant owner.
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