26 USC Subtitle A, CHAPTER 1, Subchapter N, PART III, Subpart F: Front Matter
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26 USC Subtitle A, CHAPTER 1, Subchapter N, PART III, Subpart F: Front Matter
From Title 26-INTERNAL REVENUE CODESubtitle A-Income TaxesCHAPTER 1-NORMAL TAXES AND SURTAXESSubchapter N-Tax Based on Income From Sources Within or Without the United StatesPART III-INCOME FROM SOURCES WITHOUT THE UNITED STATESSubpart F-Controlled Foreign Corporations
Jump To: MiscellaneousAmendments

Subpart F-Controlled Foreign Corporations

Sec.
951.
Amounts included in gross income of United States shareholders.
951A.
Global intangible low-taxed income included in gross income of United States shareholders.
952.
Subpart F income defined.
953.
Insurance income.
954.
Foreign base company income.
[955.
Repealed.]
956.
Investment of earnings in United States property.
[956A.
Repealed.]
957.
Controlled foreign corporations; United States persons.
958.
Rules for determining stock ownership.
959.
Exclusion from gross income of previously taxed earnings and profits.
960.
Deemed paid credit for subpart F inclusions.
961.
Adjustments to basis of stock in controlled foreign corporations and of other property.
962.
Election by individuals to be subject to tax at corporate rates.
[963.
Repealed.]
964.
Miscellaneous provisions.
965.
Treatment of deferred foreign income upon transition to participation exemption system of taxation.

        

Editorial Notes

Amendments

2017- Pub. L. 115–97, title I, §§14103(b), 14201(c), 14212(b)(6), 14301(c)(39), Dec. 22, 2017, 131 Stat. 2208 , 2213, 2217, 2225, added item 951A, substituted "Deemed paid credit for subpart F inclusions" for "Special rules for foreign tax credit" in item 960 and "Treatment of deferred foreign income upon transition to participation exemption system of taxation" for "Temporary dividends received deduction" in item 965, and struck out item 955 "Withdrawal of previously excluded subpart F income from qualified investment".

2004- Pub. L. 108–357, title IV, §422(c), Oct. 22, 2004, 118 Stat. 1519 , added item 965.

1996- Pub. L. 104–188, title I, §1501(c), Aug. 20, 1996, 110 Stat. 1826 , which directed that the analysis for subpart F be amended by striking item 956A, could not be executed, because item 956A "Earnings invested in excess passive assets" had been editorially supplied.

1986- Pub. L. 99–514, title XII, §1221(b)(3)(E), Oct. 22, 1986, 100 Stat. 2553 , substituted "Insurance income" for "Income from insurance of United States risks" in item 953.

1975- Pub. L. 94–12, title VI, §602(a)(3)(A), (c)(7), (d)(3)(B), Mar. 29, 1975, 89 Stat. 58 , 60, 64, struck out existing item 955 and replaced it with an identical item 955 and struck out item 963 "Receipt of minimum distributions by domestic corporations".

1962- Pub. L. 87–834, §12(a), Oct. 16, 1962, 76 Stat. 1006 , added heading of subpart F, and items 951–964.