Subjgrp 4. controlled foreign corporations

• § 1.960-4 - Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
• § 1.960-5 - Credit for taxable year of inclusion binding for taxable year of exclusion.
• § 1.960-6 - Overpayments resulting from increase in limitation for taxable year of exclusion.
• § 1.960-7 - Applicability dates.
• § 1.961-1 - Increase in basis of stock in controlled foreign corporations and of other property.
• § 1.961-2 - Reduction in basis of stock in foreign corporations and of other property.
• § 1.962-1 - Limitation of tax for individuals on amounts included in gross income under section 951(a).
• § 1.962-2 - Election of limitation of tax for individuals.
• § 1.962-3 - Treatment of actual distributions.
• § 1.963-0 - Repeal of section 963; effective dates.
• § 1.963-1 - [Reserved]
• § 1.963-2 - Determination of the amount of the minimum distribution.
• § 1.963-3 - Distributions counting toward a minimum distribution.
• § 1.963-4—1.963-5 - [Reserved]
• § 1.963-6 - Deficiency distribution.
• § 1.964-1 - Determination of the earnings and profits of a foreign corporation.
• § 1.964-2 - Treatment of blocked earnings and profits.
• § 1.964-3 - Records to be provided by United States shareholders.
• § 1.964-4 - Verification of certain classes of income.
• § 1.964-5 - Effective date of subpart F.
• § 1.965-0 - Outline of section 965 regulations.
• § 1.965-1 - Overview, general rules, and definitions.
• § 1.965-2 - Adjustments to earnings and profits and basis.
• § 1.965-3 - Section 965(c) deductions.
• § 1.965-4 - Disregard of certain transactions.
• § 1.965-5 - Allowance of credit or deduction for foreign income taxes.
• § 1.965-6 - Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
• § 1.965-7 - Elections, payment, and other special rules.
• § 1.965-8 - Affiliated groups (including consolidated groups).
• § 1.965-9 - Applicability dates.
• § 1.951-1 - Amounts included in gross income of United States shareholders.
• § 1.951-2 - [Reserved]
• § 1.951-3 - Coordination of subpart F with foreign personal holding company provisions.
• § 1.951A-1 - General provisions.
• § 1.951A-2 - Tested income and tested loss.
• § 1.951A-3 - Qualified business asset investment.
• § 1.951A-4 - Tested interest expense and tested interest income.
• § 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 corporation.
• § 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 -
• § 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 countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
• § 1.954-6 - Foreign base company shipping income.
• § 1.954-7 - Increase in qualified investments in foreign base company shipping operations.
• § 1.954-8 - Foreign base company oil related income.
• § 1.954(c)(6)-1 - Certain cases in which section 954(c)(6) exception not available.
• § 1.955-0 - Effective dates.
• § 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 - Amount of a controlled foreign corporation's qualified investments in less developed countries.
• § 1.955-3 - Election as to date of determining qualified investments in less developed countries.
• § 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 excluded subpart F income withdrawn from investment in foreign base company shipping operations.
• § 1.955A-2 - Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
• § 1.955A-3 - Election as to qualified investments by related persons.
• § 1.955A-4 - Election as to date of determining qualified investment in foreign base company shipping operations.
• § 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 - 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 - 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 States persons.
• § 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 of United States risks.
• § 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 previously taxed earnings and profits.
• § 1.959-2 - Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
• § 1.959-3 - Allocation of distributions to earnings and profits of foreign corporations.
• § 1.959-4 - Distributions to United States persons not counting as dividends.
• § 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 - Foreign income taxes deemed paid under sections 960(a) and (d).
• § 1.960-3 - Foreign income taxes deemed paid under section 960(b).