8964-ELE

Section 987 Elections

Agency
IRS
Revision
December 2025
Fillable fields
120
Pages
3
Official source
IRS form page
Checked
October 21, 2026
Fill 8964-ELE online
Page 1 of form 8964-ELE

Form 8964-ELE: Section 987 Elections

Form 8964-ELE is used to make or revoke elections under the section 987 regulations. The About page says it satisfies the reporting requirements of Regulations section 1.987-1(g).

Section 987 applies, the instructions say, to any taxpayer that has a qualified business unit (QBU) with a functional currency other than the dollar. Final regulations were issued on December 11, 2024 (TD 10016). The December 2025 form identifies the QBU owner and each section 987 QBU, then lists ten elections in Part III, such as the current rate election, the annual recognition election and the section 988 mark-to-market election.

The form is filed by the authorized person for the QBU owner, for example a U.S. corporation, a partnership or the controlling domestic shareholders of a controlled foreign corporation. You can fill it out free in your browser on this page and download the result without an account.

Top of page 1 of Form 8964-ELE: Section 987 Elections, as printed by IRS

What's on Form 8964-ELE

Header

The tax year, the filer's name and identifying number, the authorized person's name, identifying number and reference ID number, the address, and a Yes or No question on multiple owners or QBUs.

Part I: owner and QBU

Section A gives the QBU owner and direct owner, with country and functional currency. Section B gives the QBU's name, country, entity type, effective date, business activity, functional currency and U.S. office.

Part II: multiple owners or QBUs

Section A lists QBUs subject to the consistency rules, including QBUs of CFCs and foreign partnerships. Section B lists other QBUs. Each line asks for an attached statement.

Part III: type of election

Ten election lines, from the current rate election (line 1) to the recurring transfer group election (line 10), each with an identifying number and effective dates of the election and any revocation.

Part IV: other information

Line 1 names the representative the IRS may call, with a telephone number. Line 2 lists each CFC's controlling domestic shareholders, their TINs and percent of voting stock.

How to fill out Form 8964-ELE

  1. 1

    Filer and authorized person

    Enter the accounting period, then the filer's name and EIN or reference ID number. The instructions say a reference ID is alphanumeric, up to 50 characters, and needs no IRS application.

  2. 2

    Choose Part I or Part II

    Check Yes for multiple owners or multiple QBUs and complete only Part II. Otherwise check No and complete only Part I.

  3. 3

    QBU details

    Use two-letter country codes, the six-digit business activity code from the Form 1120 instructions, and the three-character ISO 4217 code for each functional currency. Write "branch" if the QBU is not a legal entity.

  4. 4

    Part III elections

    Check each election being made or revoked, and any earlier election still in effect. Give the EIN of the authorized person and the effective dates. For a spot rate convention, attach a statement.

  5. 5

    Part IV and statements

    Name a representative with power of attorney, such as on Form 2848. When space runs out, the instructions say to fill every space first and attach the rest, not to write "See attached".

Why fill Form 8964-ELE on indox

You get the real form, filled in a browser tab, with nothing standing between you and the finished PDF.

  • Fill the form right in your browser, no software to install
  • Free to fill and free to download, with no account
  • The official blank straight from the IRS, not a copy someone retyped
  • Works on a phone, tablet or computer

When and where to file

With the return

The instructions say the authorized person attaches Form 8964-ELE to its original, timely filed (including extensions) return for the tax year the elections are made.

Elections before the year starts

In later years, a current rate, annual recognition or section 988 mark-to-market election is filed before the start of the tax year by e-Fax to 833-312-2650, with a copy on the timely filed return.

Other elections in later years

The instructions say other elections can be made or revoked in later years only with the Commissioner's consent through a private letter ruling, with a copy attached to the return.

60-month rule

The instructions say a current rate, annual recognition or section 988 mark-to-market election may not be revoked without consent for any year beginning within 60 months of the year it was made.

Related filings

QBU owners compute pretransition gain or loss on Form 8964-TRA. Owners of foreign branches or disregarded entities may also file Form 8858.

Corrections

A corrected Form 8964-ELE is filed with an amended return, with "Corrected" at the top and a statement identifying the changes.

Related forms

Who files Form 8964-ELE?

  • U.S. persons that own a QBU

    If the QBU owner is a U.S. person, such as a domestic corporation, a domestic partnership or a citizen or resident alien, the owner is the authorized person.

  • Controlling domestic shareholders of a CFC

    If the owner is a controlled foreign corporation, its controlling domestic shareholders are treated as the authorized person, acting in concert when there are several. Part IV, line 2 lists them.

  • Consolidated groups

    For a member of a consolidated group, the common parent or other agent makes the election, and it applies to all members of the group. The common parent is listed as the filer.

  • Partnerships

    If the owner is a partnership, the instructions say the partnership itself makes or revokes the election.

  • Owners with many QBUs

    An authorized person acting for several QBU owners, or for an owner with several section 987 QBUs, answers Yes on page 1 and completes Part II instead of Part I.

The instructions say a section 987 election is made or revoked for an owner of a section 987 QBU by the authorized person, and the filer is typically that authorized person.

Official sources and the blank

Do it all with indox

View all 99 tools

Questions about Form 8964-ELE

What is Form 8964-ELE for?

The instructions say it is used to make or revoke elections under the section 987 regulations and satisfies the reporting requirements of Regulations section 1.987-1(g).

What is a section 987 QBU?

The instructions define it as an eligible qualified business unit with a functional currency different from that of its owner.

Who makes the elections for a CFC?

The instructions say the controlling domestic shareholders of the CFC are treated as the authorized person. Part IV, line 2 lists their names, TINs and percent of voting stock.

Can the form be faxed?

Only for current rate, annual recognition or section 988 mark-to-market elections in later years, filed before the tax year starts. The instructions give the e-Fax number 833-312-2650 and say to file a copy with the timely filed return.

Does an election cover every QBU the owner has?

The instructions say a section 987 election is made for an owner and a tax year, applies to every section 987 QBU the owner holds while in effect, and stays in effect until revoked.

How is a mistake corrected?

File a corrected Form 8964-ELE with an amended return, enter "Corrected" at the top and attach a statement identifying the changes.