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Title 26

Displaying title 26, up to date as of 9/08/2026. Title 26 was last amended 9/08/2026.
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  1. Title 26 —Internal Revenue
  2. Chapter I —Internal Revenue Service, Department of the Treasury
  3. Subchapter A —Income Tax
  4. Part 1 —Income Taxes
  5. Controlled Foreign Corporations   View Full Text
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Title 26Internal RevenuePart / Section
Chapter IInternal Revenue Service, Department of the Treasury1 – 899
Subchapter AIncome Tax1 – 18
Part 1Income Taxes1.0-1 – 1.9300-1
Controlled Foreign Corporations1.951-1 – 1.965-9
§ 1.951-1Amounts included in gross income of United States shareholders.
§ 1.951-2 [Reserved]
§ 1.951-3Coordination of subpart F with foreign personal holding company provisions.
§ 1.951A-1General provisions.
§ 1.951A-2Tested income and tested loss.
§ 1.951A-3Qualified business asset investment.
§ 1.951A-4Tested interest expense and tested interest income.
§ 1.951A-5Treatment of GILTI inclusion amounts.
§ 1.951A-6Adjustments related to tested losses.
§ 1.951A-7Applicability dates.
§ 1.952-1Subpart F income defined.
§ 1.952-2Determination of gross income and taxable income of a foreign corporation.
§ 1.953-1Income from insurance of United States risks.
§ 1.953-2Actual United States risks.
§ 1.953-3Risks deemed to be United States risks.
§ 1.953-4Taxable income to which section 953 applies.
§ 1.953-5Corporations not qualifying as insurance companies.
§ 1.953-6Relationship of sections 953 and 954.
§ 1.954-0Introduction.
§ 1.954-1Foreign base company income.
§ 1.954-2Foreign personal holding company income.
§ 1.954-3Foreign base company sales income.
§ 1.954-4Foreign base company services income.
§ 1.954-5Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
§ 1.954-6Foreign base company shipping income.
§ 1.954-7Increase in qualified investments in foreign base company shipping operations.
§ 1.954-8Foreign base company oil related income.
§ 1.954(c)(6)-1Certain cases in which section 954(c)(6) exception not available.
§ 1.955-0Effective dates.
§ 1.955-1Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
§ 1.955-2Amount of a controlled foreign corporation's qualified investments in less developed countries.
§ 1.955-3Election as to date of determining qualified investments in less developed countries.
§ 1.955-4Definition of less developed country.
§ 1.955-5Definition of less developed country corporation.
§ 1.955-6Gross income from sources within less developed countries.
§ 1.955A-1Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
§ 1.955A-2Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
§ 1.955A-3Election as to qualified investments by related persons.
§ 1.955A-4Election as to date of determining qualified investment in foreign base company shipping operations.
§ 1.956-1Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
§ 1.956-1TShareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
§ 1.956-2Definition of United States property.
§ 1.956-2TDefinition of United States Property (temporary).
§ 1.956-3Certain trade or service receivables acquired from United States persons.
§ 1.956-4Certain rules applicable to partnerships.
§ 1.957-1Definition of controlled foreign corporation.
§ 1.957-2Controlled foreign corporation deriving income from insurance of United States risks.
§ 1.957-3United States person defined.
§ 1.958-1Direct and indirect ownership of stock.
§ 1.958-2Constructive ownership of stock.
§ 1.959-1Exclusion from gross income of United States persons of previously taxed earnings and profits.
§ 1.959-2Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
§ 1.959-3Allocation of distributions to earnings and profits of foreign corporations.
§ 1.959-4Distributions to United States persons not counting as dividends.
§ 1.960-1Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d).
§ 1.960-2Foreign income taxes deemed paid under sections 960(a) and (d).
§ 1.960-3Foreign income taxes deemed paid under section 960(b).
§ 1.960-4Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
§ 1.960-5Credit for taxable year of inclusion binding for taxable year of exclusion.
§ 1.960-6Overpayments resulting from increase in limitation for taxable year of exclusion.
§ 1.960-7Applicability dates.
§ 1.961-1Increase in basis of stock in controlled foreign corporations and of other property.
§ 1.961-2Reduction in basis of stock in foreign corporations and of other property.
§ 1.962-1Limitation of tax for individuals on amounts included in gross income under section 951(a).
§ 1.962-2Election of limitation of tax for individuals.
§ 1.962-3Treatment of actual distributions.
§ 1.963-0Repeal of section 963; effective dates.
§ 1.963-1 [Reserved]
§ 1.963-2Determination of the amount of the minimum distribution.
§ 1.963-3Distributions counting toward a minimum distribution.
§ 1.963-4--1.963-5 [Reserved]
§ 1.963-6Deficiency distribution.
§ 1.964-1Determination of the earnings and profits of a foreign corporation.
§ 1.964-2Treatment of blocked earnings and profits.
§ 1.964-3Records to be provided by United States shareholders.
§ 1.964-4Verification of certain classes of income.
§ 1.964-5Effective date of subpart F.
§ 1.965-0Outline of section 965 regulations.
§ 1.965-1Overview, general rules, and definitions.
§ 1.965-2Adjustments to earnings and profits and basis.
§ 1.965-3Section 965(c) deductions.
§ 1.965-4Disregard of certain transactions.
§ 1.965-5Allowance of credit or deduction for foreign income taxes.
§ 1.965-6Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
§ 1.965-7Elections, payment, and other special rules.
§ 1.965-8Affiliated groups (including consolidated groups).
§ 1.965-9Applicability dates.
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