Treasury Regulations · 26 CFR
§ 1.5000C-5. Anti-abuse rule.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 5000C
Cite as 26 CFR § 1.5000C-5
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- August 18, 2016 by T.D. 9782
- Issued under
- 26 U.S.C. § 5000C
- Length
- 106 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 0 regulations; cited by 2
If a foreign person engages in a transaction (or series of transactions) with a principal purpose of avoiding the tax imposed under section 5000C, the transaction (or series of transactions) may be disregarded or the arrangement may be recharacterized (including disregarding an intermediate entity), in accordance with its substance. If this section applies, the foreign person remains liable for any tax (including any tax obligation unsatisfied as a result of underwithholding) and the Internal Revenue Service retains all other rights and remedies under any applicable law available to collect any tax imposed on the foreign contracting party by section 5000C.
[T.D. 9782, 81 FR 55138, Aug. 18, 2016]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Cited by 2 other regulations
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9782 (81 FR 55138)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Information and Returns
Nearby sections
- § 1.5000C-1 Tax on specified Federal procurement payments.
- § 1.5000C-2 Withholding on specified Federal procurement payments.
- § 1.5000C-3 Payment and returns of tax withheld by the acquiring agency.
- § 1.5000C-4 Requirement for the foreign contracting party to file a return and pay tax, and procedures for the contracting party to seek a refund.
- § 1.5000C-5 Anti-abuse rule.
- § 1.5000C-6 Examples.
- § 1.5000C-7 Effective/applicability date.