Treasury Regulations (26 C.F.R.)
26 CFR § 1.954(c)(6)-1
Certain cases in which section 954(c)(6) exception not available.
# (a) Cross-references to other rules.
For a non-exclusive list of rules that in certain cases limit the applicability of the exception to foreign personal holding company income under section 954(c)(6), see—
(1) Section 1.245A-5(d) (rules regarding the application of section 954(c)(6) to extraordinary disposition amounts);
(2) Section 1.245A-5(f) (rules regarding the application of section 954(c)(6) to tiered extraordinary reduction amounts);
(3) Section 1.245A(e)-1(c) (rules regarding tiered hybrid dividends);
(4) Section 1.367(b)-4(e)(4) (rules regarding income inclusion and gain recognition in certain exchanges following an inversion transaction);
(5) Section 964(e)(4)(A) (rules regarding certain gain from the sale or exchange of stock that is recharacterized as a dividend); and
(6) Section 1.7701(l)-4(e) (rules regarding recharacterization of certain transactions following an inversion transaction).
# (b) Applicability date.
This section applies as of August 27, 2020.
[T.D. 9909, 85 FR 53097, Aug. 27, 2020]
Source: view the official text
In this part (40 sections)
- 1.951A-5 · Treatment of GILTI inclusion amounts.
- 1.951A-6 · Adjustments related to tested losses.
- 1.951A-7 · Applicability dates.
- 1.952-1 · Subpart F income defined.
- 1.952-2 · Determination of gross income and taxable income of a foreign…
- 1.953-1 · Income from insurance of United States risks.
- 1.953-2 · Actual United States risks.
- 1.953-3 · Risks deemed to be United States risks.
- 1.953-4 · Taxable income to which section 953 applies.
- 1.953-5 · Corporations not qualifying as insurance companies.
- 1.953-6 · Relationship of sections 953 and 954.
- 1.954-0 · Introduction.
- 1.954-1 · Foreign base company income.
- 1.954-2 · Foreign personal holding company income.
- 1.954-3 · Foreign base company sales income.
- 1.954-4 · Foreign base company services income.
- 1.954-5 · Increase in qualified investments in less developed…
- 1.954-6 · Foreign base company shipping income.
- 1.954-7 · Increase in qualified investments in foreign base company…
- 1.954-8 · Foreign base company oil related income.
- 1.954(c)(6)-1 · Certain cases in which section 954(c)(6) exception not…
- 1.955-0 · Effective dates.
- 1.955-1 · Shareholder's pro rata share of amount of previously excluded…
- 1.955-2 · Amount of a controlled foreign corporation's qualified…
- 1.955-3 · Election as to date of determining qualified investments in…
- 1.955-4 · Definition of less developed country.
- 1.955-5 · Definition of less developed country corporation.
- 1.955-6 · Gross income from sources within less developed countries.
- 1.955A-1 · Shareholder's pro rata share of amount of previously…
- 1.955A-2 · Amount of a controlled foreign corporation's qualified…
- 1.955A-3 · Election as to qualified investments by related persons.
- 1.955A-4 · Election as to date of determining qualified investment in…
- 1.956-1 · Shareholder's pro rata share of the average of the amounts of…
- 1.956-1T · Shareholder's pro rata share of the average of the amounts…
- 1.956-2 · Definition of United States property.
- 1.956-2T · Definition of United States Property (temporary).
- 1.956-3 · Certain trade or service receivables acquired from United…
- 1.956-4 · Certain rules applicable to partnerships.
- 1.957-1 · Definition of controlled foreign corporation.
- 1.957-2 · Controlled foreign corporation deriving income from insurance…