U.S. Code of Federal Regulations

Regulations most recently checked for updates: Aug 27, 2025

All TitlesTitle 26Chapter IPart 1 - PART 1—INCOME TAXES (CONTINUED)

EARNED INCOME OF CITIZENS OR RESIDENTS OF UNITED STATES
§ 1.908 - [Reserved]
§ 1.909-0 - Outline of regulation provisions for section 909.
§ 1.909-1 - Definitions and special rules.
§ 1.909-2 - Splitter arrangements.
§ 1.909-3 - Rules regarding related income and split taxes.
§ 1.909-4 - Coordination rules.
§ 1.909-5 - 2011 and 2012 splitter arrangements.
§ 1.909-6 - Pre-2011 foreign tax credit splitting events.
§ 1.910 - [Reserved]
§ 1.911-1 - Partial exclusion for earned income from sources within a foreign country and foreign housing costs.
§ 1.911-2 - Qualified individuals.
§ 1.911-3 - Determination of amount of foreign earned income to be excluded.
§ 1.911-4 - Determination of housing cost amount eligible for exclusion or deduction.
§ 1.911-5 - Special rules for married couples.
§ 1.911-6 - Disallowance of deductions, exclusions, and credits.
§ 1.911-7 - Procedural rules.
§ 1.911-8 - Former deduction for certain expenses of living abroad.

EARNED INCOME OF CITIZENS OF UNITED STATES
§ 1.912-1 - Exclusion of certain cost-of-living allowances.
§ 1.912-2 - Exclusion of certain allowances of Foreign Service personnel.
§ 1.921-1T - Temporary regulations providing transition rules for DISCs and FSCs.
§ 1.921-2 - Foreign Sales Corporation—general rules.
§ 1.927(a)-1T - Temporary regulations; definition of export property.
§ 1.927(b)-1T - [Reserved]
§ 1.927(d)-1 - [Reserved]
§ 1.927(d)-2T - Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.

POSSESSIONS OF THE UNITED STATES
§ 1.931-1 - Exclusion of certain income from sources within Guam, American Samoa, or the Northern Mariana Islands.
§ 1.932-1 - Coordination of United States and Virgin Islands income taxes.
§ 1.933-1 - Exclusion of certain income from sources within Puerto Rico.
§ 1.934-1 - Limitation on reduction in income tax liability incurred to the Virgin Islands.
§ 1.935-1 - Coordination of individual income taxes with Guam and the Northern Mariana Islands.
§ 1.936-1 - Elections.
§ 1.936-4 - Intangible property income in the absence of an election out.
§ 1.936-5 - Intangible property income when an election out is made: Product, business presence, and contract manufacturing.
§ 1.936-6 - Intangible property income when an election out is made: Cost sharing and profit split options; covered intangibles.
§ 1.936-7 - Manner of making election under section 936 (h)(5); special election for export sales; revocation of election under section 936(a).
§ 1.936-8T - Qualified possession source investment income (temporary). [Reserved]
§ 1.936-9T - Source of qualified possession source investment income (temporary). [Reserved]
§ 1.936-10 - Qualified investments.
§ 1.936-11 - New lines of business prohibited.
§ 1.937-1 - Bona fide residency in a possession.
§ 1.937-2 - Income from sources within a possession.
§ 1.937-3 - Income effectively connected with the conduct of a trade or business in a possession.

CONTROLLED FOREIGN CORPORATIONS
§ 1.960-4 - Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
§ 1.960-5 - Credit for taxable year of inclusion binding for taxable year of exclusion.
§ 1.960-6 - Overpayments resulting from increase in limitation for taxable year of exclusion.
§ 1.960-7 - Applicability dates.
§ 1.961-1 - Increase in basis of stock in controlled foreign corporations and of other property.
§ 1.961-2 - Reduction in basis of stock in foreign corporations and of other property.
§ 1.962-1 - Limitation of tax for individuals on amounts included in gross income under section 951(a).
§ 1.962-2 - Election of limitation of tax for individuals.
§ 1.962-3 - Treatment of actual distributions.
§ 1.963-0 - Repeal of section 963; effective dates.
§ 1.963-1 - [Reserved]
§ 1.963-2 - Determination of the amount of the minimum distribution.
§ 1.963-3 - Distributions counting toward a minimum distribution.
§ 1.963-4—1.963-5 - [Reserved]
§ 1.963-6 - Deficiency distribution.
§ 1.964-1 - Determination of the earnings and profits of a foreign corporation.
§ 1.964-2 - Treatment of blocked earnings and profits.
§ 1.964-3 - Records to be provided by United States shareholders.
§ 1.964-4 - Verification of certain classes of income.
§ 1.964-5 - Effective date of subpart F.
§ 1.965-0 - Outline of section 965 regulations.
§ 1.965-1 - Overview, general rules, and definitions.
§ 1.965-2 - Adjustments to earnings and profits and basis.
§ 1.965-3 - Section 965(c) deductions.
§ 1.965-4 - Disregard of certain transactions.
§ 1.965-5 - Allowance of credit or deduction for foreign income taxes.
§ 1.965-6 - Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
§ 1.965-7 - Elections, payment, and other special rules.
§ 1.965-8 - Affiliated groups (including consolidated groups).
§ 1.965-9 - Applicability dates.
§ 1.951-1 - Amounts included in gross income of United States shareholders.
§ 1.951-2 - [Reserved]
§ 1.951-3 - Coordination of subpart F with foreign personal holding company provisions.
§ 1.951A-1 - General provisions.
§ 1.951A-2 - Tested income and tested loss.
§ 1.951A-3 - Qualified business asset investment.
§ 1.951A-4 - Tested interest expense and tested interest income.
§ 1.951A-5 - Treatment of GILTI inclusion amounts.
§ 1.951A-6 - Adjustments related to tested losses.
§ 1.951A-7 - Applicability dates.
§ 1.952-1 - Subpart F income defined.
§ 1.952-2 - Determination of gross income and taxable income of a foreign corporation.
§ 1.953-1 - Income from insurance of United States risks.
§ 1.953-2 - Actual United States risks.
§ 1.953-3 - Risks deemed to be United States risks.
§ 1.953-4 - Taxable income to which section 953 applies.
§ 1.953-5 - Corporations not qualifying as insurance companies.
§ 1.953-6 - Relationship of sections 953 and 954.
§ 1.954-0 - Introduction.
§ 1.954-1 - Foreign base company income.
§ 1.954-2 - Foreign personal holding company income.
§ 1.954-3 - Foreign base company sales income.
§ 1.954-4 - Foreign base company services income.
§ 1.954-5 - Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
§ 1.954-6 - Foreign base company shipping income.
§ 1.954-7 - Increase in qualified investments in foreign base company shipping operations.
§ 1.954-8 - Foreign base company oil related income.
§ 1.954(c)(6)-1 - Certain cases in which section 954(c)(6) exception not available.
§ 1.955-0 - Effective dates.
§ 1.955-1 - Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
§ 1.955-2 - Amount of a controlled foreign corporation's qualified investments in less developed countries.
§ 1.955-3 - Election as to date of determining qualified investments in less developed countries.
§ 1.955-4 - Definition of less developed country.
§ 1.955-5 - Definition of less developed country corporation.
§ 1.955-6 - Gross income from sources within less developed countries.
§ 1.955A-1 - Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
§ 1.955A-2 - Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
§ 1.955A-3 - Election as to qualified investments by related persons.
§ 1.955A-4 - Election as to date of determining qualified investment in foreign base company shipping operations.
§ 1.956-1 - Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation.
§ 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).
§ 1.956-2 - Definition of United States property.
§ 1.956-2T - Definition of United States Property (temporary).
§ 1.956-3 - Certain trade or service receivables acquired from United States persons.
§ 1.956-4 - Certain rules applicable to partnerships.
§ 1.957-1 - Definition of controlled foreign corporation.
§ 1.957-2 - Controlled foreign corporation deriving income from insurance of United States risks.
§ 1.957-3 - United States person defined.
§ 1.958-1 - Direct and indirect ownership of stock.
§ 1.958-2 - Constructive ownership of stock.
§ 1.959-1 - Exclusion from gross income of United States persons of previously taxed earnings and profits.
§ 1.959-2 - Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
§ 1.959-3 - Allocation of distributions to earnings and profits of foreign corporations.
§ 1.959-4 - Distributions to United States persons not counting as dividends.
§ 1.960-1 - Overview, definitions, and computational rules for determining foreign income taxes deemed paid under section 960(a), (b), and (d).
§ 1.960-2 - Foreign income taxes deemed paid under sections 960(a) and (d).
§ 1.960-3 - Foreign income taxes deemed paid under section 960(b).

EXPORT TRADE CORPORATIONS
§ 1.970-1 - Export trade corporations.
§ 1.970-2 - Elections as to date of determining investments in export trade assets.
§ 1.970-3 - Effective date of subpart G.
§ 1.971-1 - Definitions with respect to export trade corporations.
§ 1.972-1 - Consolidation of group of export trade corporations.
§ 1.981-0 - Repeal of section 981; effective dates.
§ 1.981-1 - Foreign law community income for taxable years beginning after December 31, 1966, and before January 1, 1977.
§ 1.981-2 - Foreign law community income for taxable years beginning before January 1, 1967.
§ 1.981-3 - Definitions and other special rules.

FOREIGN CURRENCY TRANSACTIONS
§ 1.985-0 - Outline of regulation.
§ 1.985-1 - Functional currency.
§ 1.985-2 - Election to use the United States dollar as the functional currency of a QBU.
§ 1.985-3 - United States dollar approximate separate transactions method.
§ 1.985-4 - Method of accounting.
§ 1.985-5 - Adjustments required upon change in functional currency.
§ 1.985-6 - Transition rules for a QBU that uses the dollar approximate separate transactions method for its first taxable year beginning in 1987.
§ 1.985-7 - Adjustments required in connection with a change to DASTM.
§ 1.985-8 - Special rules applicable to the European Monetary Union (conversion to euro).
§ 1.986(a)-1 - Translation of foreign income taxes for purposes of the foreign tax credit.
§ 1.986(c)-1 - Coordination with section 965.
§ 1.987-0 - Table of contents.
§ 1.987-1 - Scope, definitions, and special rules.
§ 1.987-2 - Attribution of items to eligible QBUs; definition of a transfer and related rules.
§ 1.987-3 - Determination of section 987 taxable income or loss of an owner of a section 987 QBU.
§ 1.987-3T - Determination of section 987 taxable income or loss of an owner of a section 987 QBU (temporary).
§ 1.987-4 - Determination of net unrecognized section 987 gain or loss of a section 987 QBU.
§ 1.987-5 - Recognition of section 987 gain or loss.
§ 1.987-6 - Character and source of section 987 gain or loss.
§ 1.987-6T - Character and source of section 987 gain or loss (temporary).
§ 1.987-7 - Application of the section 987 regulations to partnerships and S corporations.
§ 1.987-8 - Termination of a section 987 QBU.
§ 1.987-8T - Termination of a section 987 QBU (temporary).
§ 1.987-9 - Recordkeeping requirements.
§ 1.987-10 - Transition rules.
§ 1.987-11 -
§ 1.987-12 - Deferral of section 987 gain or loss.
§ 1.987-13 - Suspended section 987 loss upon terminations.
§ 1.987-14 - Section 987 hedging transactions.
§ 1.987-15 - Applicability date.
§ 1.988-0 - Taxation of gain or loss from a section 988 transaction; Table of Contents.
§ 1.988-1 - Certain definitions and special rules.
§ 1.988-1T - Certain definitions and special rules (temporary).
§ 1.988-2 - Recognition and computation of exchange gain or loss.
§ 1.988-2T - Recognition and computation of exchange gain or loss (temporary).
§ 1.988-3 - Character of exchange gain or loss.
§ 1.988-4 - Source of gain or loss realized on a section 988 transaction.
§ 1.988-5 - Section 988(d) hedging transactions.
§ 1.988-6 - Nonfunctional currency contingent payment debt instruments.
§ 1.989(a)-1 - Definition of a qualified business unit.
§ 1.989(b)-1 - Definition of weighted average exchange rate.

DOMESTIC INTERNATIONAL SALES CORPORATIONS
§ 1.991-1 - Taxation of a domestic international sales corporation.
§ 1.992-1 - Requirements of a DISC.
§ 1.992-2 - Election to be treated as a DISC.
§ 1.992-3 - Deficiency distributions to meet qualification requirements.
§ 1.992-4 - Coordination with personal holding company provisions in case of certain produced film rents.
§ 1.993-1 - Definition of qualified export receipts.
§ 1.993-2 - Definition of qualified export assets.
§ 1.993-3 - Definition of export property.
§ 1.993-4 - Definition of producer's loans.
§ 1.993-5 - Definition of related foreign export corporation.
§ 1.993-6 - Definition of gross receipts.
§ 1.993-7 - Definition of United States.
§ 1.994-1 - Inter-company pricing rules for DISC's.
§ 1.994-2 - Marginal costing rules.
§ 1.995-1 - Taxation of DISC income to shareholders.
§ 1.995-2 - Deemed distributions in qualified years.
§ 1.995-3 - Distributions upon disqualification.
§ 1.995-4 - Gain on disposition of stock in a DISC.
§ 1.995-5 - Foreign investment attributable to producer's loans.
§ 1.995-6 - Taxable income attributable to military property.
§ 1.996-1 - Rules for actual distributions and certain deemed distributions.
§ 1.996-2 - Ordering rules for losses.
§ 1.996-3 - Divisions of earnings and profits.
§ 1.996-4 - Subsequent effect of previous disposition of DISC stock.
§ 1.996-5 - Adjustment to basis.
§ 1.996-6 - Effectively connected income.
§ 1.996-7 - Carryover of DISC tax attributes.
§ 1.996-8 - Effect of carryback of capital loss or net operating loss to prior DISC taxable year.
§ 1.997-1 - Special rules for subchapter C of the Code.
§§ 1.998-1.1000 - §[Reserved]
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