Treasury Regulations (26 C.F.R.)
26 CFR § 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).
(a)-(e)(4) [Reserved]
(5) Exclusion for certain recourse obligations. For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (f) of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.
(e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).
(f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
(g)-(h) [Reserved]
[T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]
Source: view the official text
In this part (40 sections)
- 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 · (c)(6)-1 Certain cases in which section 954(c)(6)…
- 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…
- 1.957-3 · United States person defined.
- 1.958-1 · Direct and indirect ownership of stock.
- 1.958-2 · Constructive ownership of stock.
- 1.959-1 · Exclusion from gross income of United States persons of…
- 1.959-2 · Exclusion from gross income of controlled foreign…
- 1.959-3 · Allocation of distributions to earnings and profits of…
- 1.959-4 · Distributions to United States persons not counting as…
- 1.960-1 · Overview, definitions, and computational rules for…
- 1.960-2 · Foreign income taxes deemed paid under sections 960(a) and…
- 1.960-3 · Foreign income taxes deemed paid under section 960(b).
- 1.960-4 · Additional foreign tax credit in year of receipt of…
- 1.960-5 · Credit for taxable year of inclusion binding for taxable year…
- 1.960-6 · Overpayments resulting from increase in limitation for…