26 CFR §1.954(c)(6)-1
Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov ↗
- (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.