Treasury Regulations · 26 CFR
§ 1.956-1T. Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
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. § 956
Cite as 26 CFR § 1.956-1T
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- November 3, 2016 by T.D. 9792
- Last amended
- December 28, 2016
- Issued under
- 26 U.S.C. § 956
- Length
- 133 words · about 1 min to read
- Cross-references
- cites 1 Code section and 2 regulations; cited by 2
¶(a)-(e)(4) [Reserved]
¶(5) Exclusion for certain recourse obligations. For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (f) of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.
¶(e)
¶(f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
¶(g)-(h) [Reserved]
[T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 1.956-1 Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
- § 1.954-1 Foreign base company income.
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.
- Amended (81 FR 95471)
- Issued by T.D. 9792 (81 FR 76507)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Controlled foreign corporations
Nearby sections
- § 1.955A-2 Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
- § 1.955A-3 Election as to qualified investments by related persons.
- § 1.955A-4 Election as to date of determining qualified investment in foreign base company shipping operations.
- § 1.956-1 Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
- § 1.956-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
- § 1.956-2 Definition of United States property.
- § 1.956-2T Definition of United States Property (temporary).
- § 1.956-3 Certain trade or service receivables acquired from United States persons.
- § 1.956-4 Certain rules applicable to partnerships.