26 C.F.R. § 1.959-4

Current through October 31, 2024
Section 1.959-4 - Distributions to United States persons not counting as dividends

Except as provided in section 960(a)(3) and § 1.960-2 , any distribution to a United States person which is excluded from the gross income of such person under section 959(a)(1) and § 1.959-1 shall be treated for purposes of chapter 1 (relating to normal taxes and surtaxes) of subtitle A (relating to income taxes) of the Code as a distribution which is not a dividend. However, see paragraph (b)(1) of § 1.956-1 , relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property.

26 C.F.R. §1.959-4

T.D. 7120, 36 FR 10860, June 4, 1971