Treasury Regulations · 26 CFR
§ 1.951A-6. Adjustments related to tested losses.
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. § 951A
Cite as 26 CFR § 1.951A-6
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- June 21, 2019 by T.D. 9866
- Issued under
- 26 U.S.C. § 951A
- Length
- 114 words · about 1 min to read
- Cross-references
- cites 1 Code section and 0 regulations; cited by 3
¶(a) Scope. This section provides rules relating to adjustments related to tested losses. Paragraph (b) of this section provides rules that increase the earnings and profits of a tested loss CFC for purposes of section 952(c)(1)(A). Paragraph (c) of this section is reserved for a rule for tested loss adjustments.
¶(b) Increase of earnings and profits of tested loss CFC for purposes of section 952(c)(1)(A). For purposes of section 952(c)(1)(A) with respect to a CFC inclusion year, the earnings and profits of a tested loss CFC are increased by an amount equal to the tested loss of the tested loss CFC for the CFC inclusion year.
¶(c) [Reserved]
[T.D. 9866, 84 FR 29341, June 21, 2019]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Cited by 3 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. 9866 (84 FR 29341)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Controlled foreign corporations
Nearby sections
- § 1.951A-2 Tested income and tested loss.
- § 1.951A-3 Qualified business asset investment.
- § 1.951A-4 Tested interest expense and tested interest income.
- § 1.951A-5 Treatment of GILTI inclusion amounts.
- § 1.951A-6 Adjustments related to tested losses.
- § 1.951A-7 Applicability dates.
- § 1.952-1 Subpart F income defined.
- § 1.952-2 Determination of gross income and taxable income of a foreign corporation.
- § 1.953-1 Income from insurance of United States risks.