CONTROLLED FOREIGN CORPORATIONS

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Section 1.955-1 - Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries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Section 1.955A-1 - Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations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