Definition of Foreign Base Company Income & Foreign Personal
Holding Company Income of a Controlled Foreign Corporation

DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 8704] RIN 1545-AR31

TITLE: Definition of Foreign Base Company Income and Foreign Personal Holding Company Income of a Controlled Foreign Corporation

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations relating to the definitions of subpart F income and foreign personal holding company income of a controlled foreign corporation and the allocation of deficits for purposes of computing the deemed-paid foreign tax credit. These regulations are necessary to provide guidance that coordinates with previously published guidance under section 954. These regulations will affect United States shareholders of controlled foreign corporations.

DATES: These regulations are effective January 2, 1997. For specific dates of applicability, see 1.952-1(f)(5), 1.952-2(c)(1), 1.954-2(b)(3) and 1.960-1(i)(6).

FOR FURTHER INFORMATION CONTACT: Valerie Mark, (202) 622-3840 (not a toll-free call).

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