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Code · CFR · Title 26 — Internal Revenue · Part 1 · § 1.951A-6

§ 1.951A-6. Adjustments related to tested losses.

116 words·~1 min read·/us/cfr/t26/s§ 1.951A-6·

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(a)Scope. This section provides rules relating to adjustments related to tested losses. Paragraph
(b)of this section provides rules that increase the earnings and profits of a tested loss CFC for purposes of section 952(c)(1)(A). Paragraph
(c)of this section is reserved for a rule for tested loss adjustments.
(b)Increase of earnings and profits of tested loss CFC for purposes of section 952(c)(1)(A). For purposes of section 952(c)(1)(A) with respect to a CFC inclusion year, the earnings and profits of a tested loss CFC are increased by an amount equal to the tested loss of the tested loss CFC for the CFC inclusion year.
(c)[Reserved] [T.D. 9866, 84 FR 29341, June 21, 2019]
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  • T.D. 9866
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§ 1.951A-6
Adjustments related to tested losses.
Treas. Dec.T.D. 9866
Cites 1Cited by 0 across 0 sources
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