26 CFR Topic controlled foreign corporations | Code of Federal Regulations | US Law | LawStack Online

26 CFR Topic

controlled foreign corporations

June 25, 2020

Affiliated groups (including consolidated groups)

Applicability dates

Subpart F income defined

Determination of gross income and taxable income of a foreign corporation

Income from insurance of United States risks

Adjustments related to tested losses

Actual United States risks

Amounts included in gross income of United States shareholders

Coordination of subpart F with foreign personal holding company provisions

Outline of section 951A regulations

General provisions

Tested income and tested loss

Qualified business asset investment

Tested interest expense and tested interest income

Treatment of GILTI inclusion amounts

Risks deemed to be United States risks

Taxable income to which section 953 applies

Corporations not qualifying as insurance companies

Relationship of sections 953 and 954

Foreign base company income

Foreign personal holding company income

Foreign base company sales income

Foreign base company services income

Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976

Foreign base company shipping income

Increase in qualified investments in foreign base company shipping operations

Foreign base company oil related income

Certain cases in which section 954(c)(6) exception not available (temporary)

Effective dates

Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries

Overview, general rules, and definitions

Amount of a controlled foreign corporation's qualified investments in less developed countries

Election as to date of determining qualified investments in less developed countries

Definition of less developed country

Definition of less developed country corporation

Gross income from sources within less developed countries

Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations

Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations

Election as to qualified investments by related persons

Election as to date of determining qualified investment in foreign base company shipping operations

Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation

Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary)

Definition of United States property

Definition of United States Property (temporary)

Certain trade or service receivables acquired from United States persons

Certain rules applicable to partnerships

Definition of controlled foreign corporation

Adjustments to earnings and profits and basis

Section 965(c) deductions

Disregard of certain transactions

Allowance of credit or deduction for foreign income taxes

Computation of foreign income taxes deemed paid and allocation and apportionment of deductions

Controlled foreign corporation deriving income from insurance of United States risks

United States person defined

Direct and indirect ownership of stock

Constructive ownership of stock

Exclusion from gross income of United States persons of previously taxed earnings and profits

Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits

Allocation of distributions to earnings and profits of foreign corporations

Distributions to United States persons not counting as dividends

Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d)

Foreign income taxes deemed paid under sections 960(a) and (d)

Foreign income taxes deemed paid under section 960(b)

Additional foreign tax credit in year of receipt of previously taxed earnings and profits

Elections, payment, and other special rules

Credit for taxable year of inclusion binding for taxable year of exclusion

Overpayments resulting from increase in limitation for taxable year of exclusion

Applicability dates

Increase in basis of stock in controlled foreign corporations and of other property

Reduction in basis of stock in foreign corporations and of other property

Limitation of tax for individuals on amounts included in gross income under section 951(a)

Election of limitation of tax for individuals

Treatment of actual distributions

Repeal of section 963; effective dates

Determination of the amount of the minimum distribution

Distributions counting toward a minimum distribution

1.963-4--1.963-5

Deficiency distribution

Determination of the earnings and profits of a foreign corporation

Treatment of blocked earnings and profits

Records to be provided by United States shareholders

Verification of certain classes of income

Effective date of subpart F

Outline of section 965 regulations

Applicability dates

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