Treasury Regulations · 26 CFR
§ 1.996-6. Effectively connected income.
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. § 996
Cite as 26 CFR § 1.996-6
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- September 30, 1974 by T.D. 7324
- Issued under
- 26 U.S.C. § 996
- Length
- 183 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 3 regulations; cited by 0
In the case of a shareholder who is a nonresident alien individual or a foreign corporation, trust, or estate, amounts taxable as dividends by reason of the application of § 1.995-4 (relating to gain on disposition of stock in a DISC), amounts treated under § 1.996-1 as distributed out of accumulated DISC income, and amounts deemed distributed under § 1.995-2(a) (1) through (4) shall be treated as gains and distributions which are effectively connected with the conduct of a trade or business conducted through a permanent establishment of such shareholder within the United States, and shall be subject to tax in accordance with the provisions of section 871(b) and the regulations thereunder in the case of nonresident alien individuals, trusts, or estates, or section 882 and the regulations thereunder in the case of foreign corporations. In no case, however shall other income of such shareholder be taxable as effectively connected with the conduct of a trade or business through a permanent establishment in the United States solely because of the application of this section.
[T.D. 7324, 39 FR 35124, Sept. 30, 1974]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 871 Tax on nonresident alien individuals
- § 882 Tax on income of foreign corporations connected with United States business
Regulations 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. 7324 (39 FR 35124)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Domestic International Sales Corporations
Nearby sections
- § 1.996-2 Ordering rules for losses.
- § 1.996-3 Divisions of earnings and profits.
- § 1.996-4 Subsequent effect of previous disposition of DISC stock.
- § 1.996-5 Adjustment to basis.
- § 1.996-6 Effectively connected income.
- § 1.996-7 Carryover of DISC tax attributes.
- § 1.996-8 Effect of carryback of capital loss or net operating loss to prior DISC taxable year.
- § 1.997-1 Special rules for subchapter C of the Code.