Treasury Regulations · 26 CFR
§ 1.954(c)(6)-1. Certain cases in which section 954(c)(6) exception not available.
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. § 954(c)(6)
Cite as 26 CFR § 1.954(c)(6)-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- August 27, 2020 by T.D. 9909
- Issued under
- 26 U.S.C. § 954(c)(6)
- Length
- 165 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 0 regulations; cited by 0
¶(a) Cross-references to other rules. For a non-exclusive list of rules that in certain cases limit the applicability of the exception to foreign personal holding company income under section 954(c)(6), see—
¶(3) Section 1.245A(e)-1(c) (rules regarding tiered hybrid dividends);
¶(4) Section 1.367(b)-4(e)(4) (rules regarding income inclusion and gain recognition in certain exchanges following an inversion transaction);
¶(5) Section 964(e)(4)(A) (rules regarding certain gain from the sale or exchange of stock that is recharacterized as a dividend); and
¶(6) Section 1.7701(l)-4(e) (rules regarding recharacterization of certain transactions following an inversion transaction).
¶(b) Applicability date. This section applies as of August 27, 2020.
[T.D. 9909, 85 FR 53097, Aug. 27, 2020]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
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. 9909 (85 FR 53097)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Controlled foreign corporations
Nearby sections
- § 1.954-5 Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
- § 1.954-6 Foreign base company shipping income.
- § 1.954-7 Increase in qualified investments in foreign base company shipping operations.
- § 1.954-8 Foreign base company oil related income.
- § 1.954(c)(6)-1 Certain cases in which section 954(c)(6) exception not available.
- § 1.955-0 Effective dates.
- § 1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
- § 1.955-2 Amount of a controlled foreign corporation's qualified investments in less developed countries.
- § 1.955-3 Election as to date of determining qualified investments in less developed countries.