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Treasury Regulations · 26 CFR Part 1

Foreign corporations (§§ 1.881-0 to 1.884-5)

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. § 1.881-0 Table of contents.
  2. § 1.881-1 Manner of taxing foreign corporations.
  3. § 1.881-2 Taxation of foreign corporations not engaged in U.S. business.
  4. § 1.881-3 Conduit financing arrangements.
  5. § 1.881-4 Recordkeeping requirements concerning conduit financing arrangements.
  6. § 1.881-5 Exception for certain possessions corporations.
  7. § 1.882-0 Table of contents.
  8. § 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected income.
  9. § 1.882-2 Income of foreign corporations treated as effectively connected with U.S. business.
  10. § 1.882-3 Gross income of a foreign corporation.
  11. § 1.882-4 Allowance of deductions and credits to foreign corporations.
  12. § 1.882-5 Determination of interest deduction.
  13. § 1.883-0 Outline of major topics.
  14. § 1.883-1 Exclusion of income from the international operation of ships or aircraft.
  15. § 1.883-2 Treatment of publicly-traded corporations.
  16. § 1.883-3 Treatment of controlled foreign corporations.
  17. § 1.883-4 Qualified shareholder stock ownership test.
  18. § 1.883-5 Effective/applicability dates.
  19. § 1.884-0 Overview of regulation provisions for section 884.
  20. § 1.884-1 Branch profits tax.
  21. § 1.884-2 Special rules for termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary.
  22. § 1.884-2T Special rules for termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary (temporary).
  23. § 1.884-3T Coordination of branch profits tax with second-tier withholding (temporary).
  24. § 1.884-4 Branch-level interest tax.
  25. § 1.884-5 Qualified resident.