Code of Federal Regulations Title 26. Internal Revenue § 26.1.956–1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary)

(a) to (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).