Treasury Regulations · 26 CFR
§ 1.959-4. Distributions to United States persons not counting as 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. § 959
Cite as 26 CFR § 1.959-4
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- June 4, 1971 by T.D. 7120
- Issued under
- 26 U.S.C. § 959
- Length
- 106 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 3 regulations; cited by 0
Except as provided in section 960(a)(3) and § 1.960-2, any distribution to a United States person which is excluded from the gross income of such person under section 959(a)(1) and § 1.959-1 shall be treated for purposes of chapter 1 (relating to normal taxes and surtaxes) of subtitle A (relating to income taxes) of the Code as a distribution which is not a dividend. However, see paragraph (b)(1) of § 1.956-1, relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property.
[T.D. 7120, 36 FR 10860, June 4, 1971]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 960 Deemed paid credit for subpart F inclusions
- § 959 Exclusion from gross income of previously taxed earnings and profits
Regulations it cites
- § 1.960-2 Foreign income taxes deemed paid under sections 960(a) and (d).
- § 1.959-1 Exclusion from gross income of United States persons of previously taxed earnings and profits.
- § 1.956-1 Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
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. 7120 (36 FR 10860)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Controlled foreign corporations
Nearby sections
- § 1.958-2 Constructive ownership of stock.
- § 1.959-1 Exclusion from gross income of United States persons of previously taxed earnings and profits.
- § 1.959-2 Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
- § 1.959-3 Allocation of distributions to earnings and profits of foreign corporations.
- § 1.959-4 Distributions to United States persons not counting as dividends.
- § 1.960-1 Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d).
- § 1.960-2 Foreign income taxes deemed paid under sections 960(a) and (d).
- § 1.960-3 Foreign income taxes deemed paid under section 960(b).
- § 1.960-4 Additional foreign tax credit in year of receipt of previously taxed earnings and profits.