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Code of Federal Regulations Title 26. Internal Revenue § 26.1.954(c)(6)–1 Certain cases in which section 954(c)(6) exception not available

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

(a) Cross-references to other rules. For a non-exclusive list of rules that in certain cases limit the applicability of the exception to foreign personal holding company income under section 954(c)(6), see—

(1)Section 1.245A–5(d) (rules regarding the application of section 954(c)(6) to extraordinary disposition amounts);

(2)Section 1.245A–5(f) (rules regarding the application of section 954(c)(6) to tiered extraordinary reduction amounts);

(3) Section 1.245A(e)–1(c) (rules regarding tiered hybrid dividends);

(4)Section 1.367(b)–4(e)(4) (rules regarding income inclusion and gain recognition in certain exchanges following an inversion transaction);

(5)Section 964(e)(4)(A) (rules regarding certain gain from the sale or exchange of stock that is recharacterized as a dividend);  and

(6)Section 1.7701(l)–4(e) (rules regarding recharacterization of certain transactions following an inversion transaction).

(b) Applicability date. This section applies as of August 27, 2020.

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Cite this article: FindLaw.com - Code of Federal Regulations Title 26. Internal Revenue § 26.1.954(c)(6)–1 Certain cases in which section 954(c)(6) exception not available - last updated January 02, 2025 | https://codes.findlaw.com/cfr/title-26-internal-revenue/cfr-sect-26-1-954-c-6-1/

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