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Code of Federal Regulations (Last Updated: July 5, 2024) |
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Title 26 - Internal Revenue |
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Chapter I - Internal Revenue Service, Department of the Treasury |
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SubChapter A - Income Tax |
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Part 1 - Income Taxes |
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Controlled Foreign Corporations |
§ 1.959-4 - Distributions to United States persons not counting as dividends.
Latest version.
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§ 1.959-4 Distributions to United States persons not counting as dividends.
Except as provided in section 960(a)(3) and § 1.960-2, any distribution to a United States person which is excluded from the gross income of such person under section 959(a)(1) and § 1.959-1 shall be treated for purposes of chapter 1 (relating to normal taxes and surtaxes) of subtitle A (relating to income taxes) of the Code as a distribution which is not a dividend. However, see paragraph (b)(1) of § 1.956-1, relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property.
[T.D. 7120, 36 FR 10860, June 4, 1971]