26 CFR §1.954-5
Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov ↗
For rules applicable to taxable years of controlled foreign corporations beginning before January 1, 1976, see section 954(b)(1) (as in effect before the enactment of the Tax Reduction Act of 1975) and 26 CFR 1.954-5 (Revised as of April 1, 1975).