Definition of Foreign Base Company Income and Foreign Personal Holding Company Income of a Controlled Foreign Corporation
other · IRS · Rule · Published 1997-01-02 · Effective 1997-01-02 · 62 FR 17
Document
Document number
97-32378
Federal Register citation
62 FR 17
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
1997-01-02
Effective date
1997-01-02
Treasury docket
TD 8704
Abstract
This document contains final regulations relating to the definitions of subpart F income and foreign personal holding company income of a controlled foreign corporation and the allocation of deficits for purposes of computing the deemed-paid foreign tax credit. These regulations are necessary to provide guidance that coordinates with previously published guidance under section 954. These regulations will affect United States shareholders of controlled foreign corporations.