Controlled Foreign Corporations

Sections

• 1.951-1
  § 1.951-1 Amounts included in gross income of United States shareholders.
• 1.951-2
  § 1.951-2 [Reserved]
• 1.951-3
  § 1.951-3 Coordination of subpart F with foreign personal holding company provisions.
• 1.951A-1
  § 1.951A-1 General provisions.
• 1.951A-2
  § 1.951A-2 Tested income and tested loss.
• 1.951A-3
  § 1.951A-3 Qualified business asset investment.
• 1.951A-4
  § 1.951A-4 Tested interest expense and tested interest income.
• 1.951A-5
  § 1.951A-5 Treatment of GILTI inclusion amounts.
• 1.951A-6
  § 1.951A-6 Adjustments related to tested losses.
• 1.951A-7
  § 1.951A-7 Applicability dates.
• 1.952-1
  § 1.952-1 Subpart F income defined.
• 1.952-2
  § 1.952-2 Determination of gross income and taxable income of a foreign corporation.
• 1.953-1
  § 1.953-1 Income from insurance of United States risks.
• 1.953-2
  § 1.953-2 Actual United States risks.
• 1.953-3
  § 1.953-3 Risks deemed to be United States risks.
• 1.953-4
  § 1.953-4 Taxable income to which section 953 applies.
• 1.953-5
  § 1.953-5 Corporations not qualifying as insurance companies.
• 1.953-6
  § 1.953-6 Relationship of sections 953 and 954.
• 1.954-0
  § 1.954-0 Introduction.
• 1.954-1
  § 1.954-1 Foreign base company income.
• 1.954-2
  § 1.954-2 Foreign personal holding company income.
• 1.954-3
  § 1.954-3 Foreign base company sales income.
• 1.954-4
  § 1.954-4 Foreign base company services income.
• 1.954-5
  § 1.954-5 Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
• 1.954-6
  § 1.954-6 Foreign base company shipping income.
• 1.954-7
  § 1.954-7 Increase in qualified investments in foreign base company shipping operations.
• 1.954-8
  § 1.954-8 Foreign base company oil related income.
• 1.954(c)(6)-1
  § 1.954(c)(6)-1 Certain cases in which section 954(c)(6) exception not available.
• 1.955-0
  § 1.955-0 Effective dates.
• 1.955-1
  § 1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
• 1.955-2
  § 1.955-2 Amount of a controlled foreign corporation's qualified investments in less developed countries.
• 1.955-3
  § 1.955-3 Election as to date of determining qualified investments in less developed countries.
• 1.955-4
  § 1.955-4 Definition of less developed country.
• 1.955-5
  § 1.955-5 Definition of less developed country corporation.
• 1.955-6
  § 1.955-6 Gross income from sources within less developed countries.
• 1.955A-1
  § 1.955A-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
• 1.955A-2
  § 1.955A-2 Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
• 1.955A-3
  § 1.955A-3 Election as to qualified investments by related persons.
• 1.955A-4
  § 1.955A-4 Election as to date of determining qualified investment in foreign base company shipping operations.
• 1.956-1
  § 1.956-1 Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
• 1.956-1T
  § 1.956-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
• 1.956-2
  § 1.956-2 Definition of United States property.
• 1.956-2T
  § 1.956-2T Definition of United States Property (temporary).
• 1.956-3
  § 1.956-3 Certain trade or service receivables acquired from United States persons.
• 1.956-4
  § 1.956-4 Certain rules applicable to partnerships.
• 1.957-1
  § 1.957-1 Definition of controlled foreign corporation.
• 1.957-2
  § 1.957-2 Controlled foreign corporation deriving income from insurance of United States risks.
• 1.957-3
  § 1.957-3 United States person defined.
• 1.958-1
  § 1.958-1 Direct and indirect ownership of stock.
• 1.958-2
  § 1.958-2 Constructive ownership of stock.
• 1.959-1
  § 1.959-1 Exclusion from gross income of United States persons of previously taxed earnings and profits.
• 1.959-2
  § 1.959-2 Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
• 1.959-3
  § 1.959-3 Allocation of distributions to earnings and profits of foreign corporations.
• 1.959-4
  § 1.959-4 Distributions to United States persons not counting as dividends.
• 1.960-1
  § 1.960-1 Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d).
• 1.960-2
  § 1.960-2 Foreign income taxes deemed paid under sections 960(a) and (d).
• 1.960-3
  § 1.960-3 Foreign income taxes deemed paid under section 960(b).
• 1.960-4
  § 1.960-4 Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
• 1.960-5
  § 1.960-5 Credit for taxable year of inclusion binding for taxable year of exclusion.
• 1.960-6
  § 1.960-6 Overpayments resulting from increase in limitation for taxable year of exclusion.
• 1.960-7
  § 1.960-7 Applicability dates.
• 1.961-1
  § 1.961-1 Increase in basis of stock in controlled foreign corporations and of other property.
• 1.961-2
  § 1.961-2 Reduction in basis of stock in foreign corporations and of other property.
• 1.962-1
  § 1.962-1 Limitation of tax for individuals on amounts included in gross income under section 951(a).
• 1.962-2
  § 1.962-2 Election of limitation of tax for individuals.
• 1.962-3
  § 1.962-3 Treatment of actual distributions.
• 1.963-0
  § 1.963-0 Repeal of section 963; effective dates.
• 1.963-1
  § 1.963-1 [Reserved]
• 1.963-2
  § 1.963-2 Determination of the amount of the minimum distribution.
• 1.963-3
  § 1.963-3 Distributions counting toward a minimum distribution.
• 1.963-4 - 1.963-5
  § 1.963-4--1.963-5 [Reserved]
• 1.963-6
  § 1.963-6 Deficiency distribution.
• 1.964-1
  § 1.964-1 Determination of the earnings and profits of a foreign corporation.
• 1.964-2
  § 1.964-2 Treatment of blocked earnings and profits.
• 1.964-3
  § 1.964-3 Records to be provided by United States shareholders.
• 1.964-4
  § 1.964-4 Verification of certain classes of income.
• 1.964-5
  § 1.964-5 Effective date of subpart F.
• 1.965-0
  § 1.965-0 Outline of section 965 regulations.
• 1.965-1
  § 1.965-1 Overview, general rules, and definitions.
• 1.965-2
  § 1.965-2 Adjustments to earnings and profits and basis.
• 1.965-3
  § 1.965-3 Section 965(c) deductions.
• 1.965-4
  § 1.965-4 Disregard of certain transactions.
• 1.965-5
  § 1.965-5 Allowance of credit or deduction for foreign income taxes.
• 1.965-6
  § 1.965-6 Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
• 1.965-7
  § 1.965-7 Elections, payment, and other special rules.
• 1.965-8
  § 1.965-8 Affiliated groups (including consolidated groups).
• 1.965-9
  § 1.965-9 Applicability dates.