26 C.F.R. § 1.959-4. - § 1.959-4 Distributions to United States Persons Not Counting as Dividends.

Current as of January 1, 1970

Section 1.959-4 - § 1.959-4 Distributions to United States Persons Not Counting as Dividends.Section 1.959-4 - § 1.959-4 Distributions to United States Persons Not Counting as Dividends.

Section 1.959-3 - § 1.959-3 Allocation of Distributions to Earnings and Profits of Foreign Corporations.Section 1.960-1 - § 1.960-1 Overview, Definitions, and Computational Rules for Determining Foreign Income Taxes Deemed Paid Under Section 960(a), (b), and (d).

§ 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]

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