§ 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).
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/us/cfr/t26/s§ 1.956-1T·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)-(e)(4) [Reserved]
(5)Exclusion for certain recourse obligations. For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph
(f)of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation. (e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).
(f)Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988. (g)-(h) [Reserved] [T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]
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§ 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).
Treas. Dec.T.D. 9792
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