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Treasury Regulations (26 C.F.R.)

26 CFR § 1.951A-6

Adjustments related to tested losses.

Official textecfr.govlast amended

# (a) Scope.

This section provides rules relating to adjustments related to tested losses. Paragraph (b) of this section provides rules that increase the earnings and profits of a tested loss CFC for purposes of section 952(c)(1)(A). Paragraph (c) of this section is reserved for a rule for tested loss adjustments.

# (b) Increase of earnings and profits of tested loss CFC for purposes of section 952(c)(1)(A).

For purposes of section 952(c)(1)(A) with respect to a CFC inclusion year, the earnings and profits of a tested loss CFC are increased by an amount equal to the tested loss of the tested loss CFC for the CFC inclusion year.

# (c)

[Reserved]

[T.D. 9866, 84 FR 29341, June 21, 2019]

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In this part (40 sections)
  1. 1.936-1 · Elections.
  2. 1.936-4 · Intangible property income in the absence of an election out.
  3. 1.936-5 · Intangible property income when an election out is made:…
  4. 1.936-6 · Intangible property income when an election out is made: Cost…
  5. 1.936-7 · Manner of making election under section 936 (h)(5); special…
  6. 1.936-8T · Qualified possession source investment income (temporary).…
  7. 1.936-9T · Source of qualified possession source investment income…
  8. 1.936-10 · Qualified investments.
  9. 1.936-11 · New lines of business prohibited.
  10. 1.937-1 · Bona fide residency in a possession.
  11. 1.937-2 · Income from sources within a possession.
  12. 1.937-3 · Income effectively connected with the conduct of a trade or…
  13. 1.951-1 · Amounts included in gross income of United States…
  14. 1.951-2 · [Reserved]
  15. 1.951-3 · Coordination of subpart F with foreign personal holding…
  16. 1.951A-1 · General provisions.
  17. 1.951A-2 · Tested income and tested loss.
  18. 1.951A-3 · Qualified business asset investment.
  19. 1.951A-4 · Tested interest expense and tested interest income.
  20. 1.951A-5 · Treatment of GILTI inclusion amounts.
  21. 1.951A-6 · Adjustments related to tested losses.
  22. 1.951A-7 · Applicability dates.
  23. 1.952-1 · Subpart F income defined.
  24. 1.952-2 · Determination of gross income and taxable income of a foreign…
  25. 1.953-1 · Income from insurance of United States risks.
  26. 1.953-2 · Actual United States risks.
  27. 1.953-3 · Risks deemed to be United States risks.
  28. 1.953-4 · Taxable income to which section 953 applies.
  29. 1.953-5 · Corporations not qualifying as insurance companies.
  30. 1.953-6 · Relationship of sections 953 and 954.
  31. 1.954-0 · Introduction.
  32. 1.954-1 · Foreign base company income.
  33. 1.954-2 · Foreign personal holding company income.
  34. 1.954-3 · Foreign base company sales income.
  35. 1.954-4 · Foreign base company services income.
  36. 1.954-5 · Increase in qualified investments in less developed…
  37. 1.954-6 · Foreign base company shipping income.
  38. 1.954-7 · Increase in qualified investments in foreign base company…
  39. 1.954-8 · Foreign base company oil related income.
  40. 1.954(c)(6)-1 · (c)(6)-1 Certain cases in which section 954(c)(6)…
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