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Treasury Regulations · 26 CFR Part 1

Controlled foreign corporations (§§ 1.951-1 to 1.965-9)

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 Title 26 on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

  1. § 1.951-1 Amounts included in gross income of United States shareholders.
  2. § 1.951-2 [Reserved]
  3. § 1.951-3 Coordination of subpart F with foreign personal holding company provisions.
  4. § 1.951A-1 General provisions.
  5. § 1.951A-2 Tested income and tested loss.
  6. § 1.951A-3 Qualified business asset investment.
  7. § 1.951A-4 Tested interest expense and tested interest income.
  8. § 1.951A-5 Treatment of GILTI inclusion amounts.
  9. § 1.951A-6 Adjustments related to tested losses.
  10. § 1.951A-7 Applicability dates.
  11. § 1.952-1 Subpart F income defined.
  12. § 1.952-2 Determination of gross income and taxable income of a foreign corporation.
  13. § 1.953-1 Income from insurance of United States risks.
  14. § 1.953-2 Actual United States risks.
  15. § 1.953-3 Risks deemed to be United States risks.
  16. § 1.953-4 Taxable income to which section 953 applies.
  17. § 1.953-5 Corporations not qualifying as insurance companies.
  18. § 1.953-6 Relationship of sections 953 and 954.
  19. § 1.954-0 Introduction.
  20. § 1.954-1 Foreign base company income.
  21. § 1.954-2 Foreign personal holding company income.
  22. § 1.954-3 Foreign base company sales income.
  23. § 1.954-4 Foreign base company services income.
  24. § 1.954-5 Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
  25. § 1.954-6 Foreign base company shipping income.
  26. § 1.954-7 Increase in qualified investments in foreign base company shipping operations.
  27. § 1.954-8 Foreign base company oil related income.
  28. § 1.954(c)(6)-1 Certain cases in which section 954(c)(6) exception not available.
  29. § 1.955-0 Effective dates.
  30. § 1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
  31. § 1.955-2 Amount of a controlled foreign corporation's qualified investments in less developed countries.
  32. § 1.955-3 Election as to date of determining qualified investments in less developed countries.
  33. § 1.955-4 Definition of less developed country.
  34. § 1.955-5 Definition of less developed country corporation.
  35. § 1.955-6 Gross income from sources within less developed countries.
  36. § 1.955A-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
  37. § 1.955A-2 Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
  38. § 1.955A-3 Election as to qualified investments by related persons.
  39. § 1.955A-4 Election as to date of determining qualified investment in foreign base company shipping operations.
  40. § 1.956-1 Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
  41. § 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).
  42. § 1.956-2 Definition of United States property.
  43. § 1.956-2T Definition of United States Property (temporary).
  44. § 1.956-3 Certain trade or service receivables acquired from United States persons.
  45. § 1.956-4 Certain rules applicable to partnerships.
  46. § 1.957-1 Definition of controlled foreign corporation.
  47. § 1.957-2 Controlled foreign corporation deriving income from insurance of United States risks.
  48. § 1.957-3 United States person defined.
  49. § 1.958-1 Direct and indirect ownership of stock.
  50. § 1.958-2 Constructive ownership of stock.
  51. § 1.959-1 Exclusion from gross income of United States persons of previously taxed earnings and profits.
  52. § 1.959-2 Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
  53. § 1.959-3 Allocation of distributions to earnings and profits of foreign corporations.
  54. § 1.959-4 Distributions to United States persons not counting as dividends.
  55. § 1.960-1 Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d).
  56. § 1.960-2 Foreign income taxes deemed paid under sections 960(a) and (d).
  57. § 1.960-3 Foreign income taxes deemed paid under section 960(b).
  58. § 1.960-4 Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
  59. § 1.960-5 Credit for taxable year of inclusion binding for taxable year of exclusion.
  60. § 1.960-6 Overpayments resulting from increase in limitation for taxable year of exclusion.
  61. § 1.960-7 Applicability dates.
  62. § 1.961-1 Increase in basis of stock in controlled foreign corporations and of other property.
  63. § 1.961-2 Reduction in basis of stock in foreign corporations and of other property.
  64. § 1.962-1 Limitation of tax for individuals on amounts included in gross income under section 951(a).
  65. § 1.962-2 Election of limitation of tax for individuals.
  66. § 1.962-3 Treatment of actual distributions.
  67. § 1.963-0 Repeal of section 963; effective dates.
  68. § 1.963-1 [Reserved]
  69. § 1.963-2 Determination of the amount of the minimum distribution.
  70. § 1.963-3 Distributions counting toward a minimum distribution.
  71. § 1.963-4 - 1.963-5 [Reserved]
  72. § 1.963-6 Deficiency distribution.
  73. § 1.964-1 Determination of the earnings and profits of a foreign corporation.
  74. § 1.964-2 Treatment of blocked earnings and profits.
  75. § 1.964-3 Records to be provided by United States shareholders.
  76. § 1.964-4 Verification of certain classes of income.
  77. § 1.964-5 Effective date of subpart F.
  78. § 1.965-0 Outline of section 965 regulations.
  79. § 1.965-1 Overview, general rules, and definitions.
  80. § 1.965-2 Adjustments to earnings and profits and basis.
  81. § 1.965-3 Section 965(c) deductions.
  82. § 1.965-4 Disregard of certain transactions.
  83. § 1.965-5 Allowance of credit or deduction for foreign income taxes.
  84. § 1.965-6 Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
  85. § 1.965-7 Elections, payment, and other special rules.
  86. § 1.965-8 Affiliated groups (including consolidated groups).
  87. § 1.965-9 Applicability dates.