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Code of Federal Regulations Title 26. Internal Revenue § 26.1.951A–6 Adjustments related to tested losses

Current as of January 02, 2025 | Updated by Findlaw Staff

(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]

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Cite this article: FindLaw.com - Code of Federal Regulations Title 26. Internal Revenue § 26.1.951A–6 Adjustments related to tested losses - last updated January 02, 2025 | https://codes.findlaw.com/cfr/title-26-internal-revenue/cfr-sect-26-1-951a-6/

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