Thus, there is a cliff effect: if even a de minimis amount of income or gain from the transaction or property is subpart F income, the entire amount of the foreign currency gain or loss from the transaction or property, or from a bona fide hedging transaction with respect to the transaction or property, is included in the FPHCI computation.
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VPLAN - (no access) - 2017-27320 988 regs.pdf, p8
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