26 CFR 1.959-4
§ 1.959-4 Distributions to United States persons not counting as dividends.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 1.959-4, § 1.959-4 Distributions to United States persons not counting as dividends, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/111302
- Permanent ID
ys:prov:111302@1- SHA-256
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Full text
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.
Legislative history
This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.