§951A. Net CFC tested income included in gross income of United States shareholders — Inbound Citations
26 U.S.C. § 951A
Cited by 13 provisions in release 119-102.
Citations to 26 U.S.C. § 951A as a whole
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(C) In the case of any corporation which is not included on a consolidated return with the taxpayer, adjusted financial statement income of the taxpayer with respect to such other corporation shall be determined by only taking into account the dividends received from such other corporation (reduced to the extent provided by the Secretary in regulations or other guidance) and other amounts which are includible in gross income or deductible as a loss under this chapter (other than amounts required to be included under sections 951 and 951A or such other amounts as provided by the Secretary) with respect to such other corporation.
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(i) the net CFC tested income amount (if any) which is included in the gross income of such domestic corporation under section 951A for such taxable year, and
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(II) the net CFC tested income included in the gross income of such corporation under section 951A,
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(A) any amount includible in gross income under section 951A (other than passive category income),
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(1) this subpart (other than sections 951A, 951(b), and 957) shall be applied with respect to such shareholder (separately from, and in addition to, the application of this subpart without regard to this section)—(A) by substituting “foreign controlled United States shareholder” for “United States shareholder” each place it appears therein, and(B) by substituting “foreign controlled foreign corporation” for “controlled foreign corporation” each place it appears therein, and
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(2) section 951A (and such other provisions of this subpart as provided by the Secretary) shall be applied with respect to such shareholder—(A) by treating each reference to “United States shareholder” in such section as including a reference to such shareholder, and(B) by treating each reference to “controlled foreign corporation” in such section as including a reference to such foreign controlled foreign corporation.
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(1) For purposes of subpart A of this part, if any amount is includible in the gross income of a domestic corporation under section 951A, such domestic corporation shall be deemed to have paid foreign income taxes equal to 90 percent of the product of—(A) such domestic corporation’s inclusion percentage, multiplied by(B) the aggregate tested foreign income taxes paid or accrued by controlled foreign corporations.
Citations to §951A(a)
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(vi) the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and
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(4) No credit shall be allowed under section 901 for 10 percent of any foreign income taxes paid or accrued (or deemed paid under subsection (b)(1)) with respect to any amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a).
Citations to §951A(b)
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(A) such corporation’s net CFC tested income (as defined in section 951A(b)), divided by
Citations to §951A(b)(1)(A)
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(B) the aggregate amount described in section 951A(b)(1)(A) with respect to such corporation.