26 C.F.R. § 1.956-1T. - § 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).

Current as of January 1, 1970

Section 1.956-1T - § 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).Section 1.956-1T - § 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).

Section 1.956-1 - § 1.956-1 Shareholder's Pro Rata Share of the Average of the Amounts of United States Property Held by a Controlled Foreign Corporation.Section 1.956-2 - § 1.956-2 Definition of United States Property.

§ 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]

Disclaimer. This may not be the most current version of this information. Users should consult official sources to verify information on this site is recent and current. Marble does not warrant or represent the accuracy, completeness or reliability of the information contained on this site.