Code of Federal Regulations Title 26. Internal Revenue § 26.1.959–4 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.