Treasury Regulations · 26 CFR
§ 1.860-1. Deficiency dividends.
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. § 860
Cite as 26 CFR § 1.860-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- January 18, 1984 by T.D. 7936
- Issued under
- 26 U.S.C. § 860
- Length
- 202 words · about 1 min to read
- Cross-references
- cites 5 Code sections and 1 regulation; cited by 1
Section 860 allows a qualified investment entity to be relieved from the payment of a deficiency in (or to be allowed a credit or refund of) certain taxes. “Qualified investment entity” is defined in section 860(b). The taxes referred to are those imposed by sections 852(b)(1) and (3), 857(b)(1) or (3), the minimum tax on tax preferences imposed by section 56 and, if the entity fails the distribution requirements of section 852(a)(1)(A) or 857(a)(1) (as applicable), the corporate income tax imposed by section 11(a) or 1201(a). The method provided by section 860 is to allow an additional deduction for a dividend distribution (that meets the requirements of section 860 and § 1.860-2) in computing the deduction for dividends paid for the taxable year for which the deficiency is determined. A deficiency divided may be an ordinary dividend or, subject to the limitations of sections 852(b)(3)(C), 857(b)(3)(C), and 860(f)(2)(B), may be a capital gain dividend.
(Sec. 7805, 68A Stat. 917; 26 U.S.C. 7805; sec. 860(e) (92 Stat. 2849, 26 U.S.C. 860(e)); sec. 860(g) (92 Stat. 2850, 26 U.S.C. 860(g)))
[T.D. 7936, 49 FR 2107, Jan. 18, 1984]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 860 Deduction for deficiency dividends
- § 852 Taxation of regulated investment companies and their shareholders
- § 56 Adjustments in computing alternative minimum taxable income
- § 11 Tax imposed
- § 7805 Rules and regulations
Regulations it cites
Cited by 1 other regulation
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. 7936 (49 FR 2107)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Real Estate Investment Trusts
Nearby sections
- § 1.857-9 Information required in returns of shareholders.
- § 1.857-10 Information returns.
- § 1.857-11 Non-REIT earnings and profits.
- § 1.858-1 Dividends paid by a real estate investment trust after close of taxable year.
- § 1.860-1 Deficiency dividends.
- § 1.860-2 Requirements for deficiency dividends.
- § 1.860-3 Interest and additions to tax.
- § 1.860-4 Claim for credit or refund.
- § 1.860-5 Effective date.