Code of Federal Regulations (Last Updated: July 5, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter A - Income Tax |
Part 1 - Income Taxes |
Controlled Foreign Corporations |
§ 1.956-1T - Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
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§ 1.956-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
(a)-(e) (4) [Reserved]
(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.
(e) (6) [Reserved] . For further guidance, see § 1.956-1(e)(6).
(f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
(g)-(h) [Reserved]
[T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]