StacksVerified U.S. regulatory reference

26 CFR §1.956-1T

Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov
  1. (a)-(e)(4) [Reserved]
    1. (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.
  2. (e)
    1. (6)[Reserved] For further guidance, see § 1.956-1(e)(6).
  3. (f)Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
  4. (g)-(h) [Reserved]