Our foreign earnings cannot be converted or remitted because of currency controls. Can we omit the income automatically?
Foreign currency controls do not automatically allow omission of income.
By AE Tax Advisors Team · Updated October 29, 2026
Foreign currency controls do not automatically allow omission of income. A specific blocked-income deferral procedure may be available under IRS guidance when its requirements are satisfied, but ordinary foreign-account inconvenience is not enough. Income recognition, permitted restrictions and the required reporting position must be established.
A specific business-owner situation
A taxpayer earns income abroad but cannot freely convert or remit it because of government restrictions. Leaving it off the return without explanation can misstate the tax position even if no dollars reached the United States.
Illustrative example, not a client result.
What to establish before filing
- Identify the legal restrictions and income rights.
- Review eligibility for the blocked-income procedure.
- Maintain the required records and later inclusion trigger.
Which fact changes the answer?
Government conversion restrictions differ from voluntary retention of earnings abroad. The specific rule must actually cover the taxpayer and income.
A mistake to avoid
Do not equate a bank's processing delay with qualifying blocked income.
Records that support the decision
- Foreign legal restrictions.
- Income and account statements.
- Deferral statement and release history.
The decision to document
Have the international preparer document any valid deferral and track when access or conversion later requires recognition.
Business-owner tax planning and preparation scope · Discuss advisory scope with AE
Related questions
- We accrued a foreign supplier invoice, then paid at a different exchange rate. Do we revise the original inventory cost?
- Our foreign-currency business bank balance rose in dollar value. Is that entire increase automatically taxable now?
Sources and editorial context
- Section 988: foreign-currency transactions
- IRS: functional currency and exchange rates
- IRS Publication 54: blocked income and foreign-currency restrictions
General educational information prepared with AI assistance. No individual professional review is claimed. Apply the relevant tax-year rules to the actual records. Editorial policy · AI disclosure.