# Special Rules Regarding Certain Section 951 Pro Rata Share Allocations
> **IRS** · Final regulations. · Published 2006-02-22 · Effective 2006-02-22 · 71 FR 8943
## Document
- **Document number:** 06-1532
- **Category:** tax-irs
- **Sub-agency:** IRS
- **Federal Register citation:** 71 FR 8943
- **CFR reference:** 26 CFR 1
- **Publication date:** 2006-02-22
- **Effective date:** 2006-02-22
- **Treasury docket:** TD 9251
## Abstract

This document contains final regulations under section 951(a) of the Internal Revenue Code (Code) regarding a United States shareholder's pro rata share of a controlled foreign corporation's (CFC's) subpart F income, previously excluded subpart F income withdrawn from investment in less developed countries, and previously excluded subpart F income withdrawn from foreign base country shipping operations. These regulations are intended to ensure that a CFC's earnings and profits for a taxable year attributable to a section 304 transaction will not be allocated in a manner that results in the avoidance of Federal income tax. These regulations are also intended to ensure that earnings and profits of a CFC are not allocated to certain preferred stock in a manner inconsistent with the economic interest that such stock represents.

## Source
- [Federal Register document](https://www.federalregister.gov/documents/2006/02/22/06-1532/special-rules-regarding-certain-section-951-pro-rata-share-allocations)
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