26 CFR 1.5000C-5
§ 1.5000C-5 Anti-abuse rule.
United States · 26 CFR — Internal Revenue · Status: effective
Cite this
- Citation
- 26 CFR 1.5000C-5, § 1.5000C-5 Anti-abuse rule, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/112012
- Permanent ID
ys:prov:112012@1- SHA-256
ccdc813c64759ee0a4350b6b8c1321b247cc36ec5f27ffc46ebd7b62fdc71b23
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Full text
If a foreign person engages in a transaction (or series of transactions) with a principal purpose of avoiding the tax imposed under section 5000C, the transaction (or series of transactions) may be disregarded or the arrangement may be recharacterized (including disregarding an intermediate entity), in accordance with its substance. If this section applies, the foreign person remains liable for any tax (including any tax obligation unsatisfied as a result of underwithholding) and the Internal Revenue Service retains all other rights and remedies under any applicable law available to collect any tax imposed on the foreign contracting party by section 5000C.
Legislative history
This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.