Sec. 323. EXTENSION OF LOOK-THRU TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS UNDER FOREIGN PERSONAL HOLDING COMPANY RULES

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## SEC. 323 EXTENSION OF LOOK-THRU TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS UNDER FOREIGN PERSONAL HOLDING COMPANY RULES ###

(a)In General **[**[26 U.S.C. 954](/us/usc/t26/s954)**]** Subparagraph

(C)of section 954(c)(6) is amended by striking “January 1, 2012” and inserting “January 1, 2014”. ###

(b)Effective Date **[**[26 U.S.C. 954 note](/us/usc/t26/s954)**]** The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2011, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end.

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U.S. Code

Foreign base company income
§ 954

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Sec. 323

EXTENSION OF LOOK-THRU TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS UNDER FOREIGN PERSONAL HOLDING COMPANY RULES

U.S.C.§ 954

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