2023-01-25
Yesterday the IRS published average currency exchange rates for 2022. These average rates are used on Schedules H and M of Form 5471. In addition, the average exchange rates are used to convert local currency Subpart F Income and GILTI tested income amounts into U.S. dollars. Code §989(b)(3).
The average exchange rates are also used to convert GILTI inclusion amounts back into the functional currency of the CFCs. See Form 8992, Schedule A, Column (l) and Treas. Reg. §1.951A-5(b)(3).
The Treasury Department has also published year-end currency exchange rates for 2022. These year-end exchange rates are used on Form 8938 and the FBAR.