# Treas. Reg. § 1.951A-6: Adjustments related to tested losses.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-1.951A-6>. Interprets 26 U.S.C. § 951A.

(a) Scope. This section provides rules relating to adjustments related to tested losses. Paragraph (b) of this section provides rules that increase the earnings and profits of a tested loss CFC for purposes of section 952(c)(1)(A). Paragraph (c) of this section is reserved for a rule for tested loss adjustments. 

(b) Increase of earnings and profits of tested loss CFC for purposes of section 952(c)(1)(A). For purposes of section 952(c)(1)(A) with respect to a CFC inclusion year, the earnings and profits of a tested loss CFC are increased by an amount equal to the tested loss of the tested loss CFC for the CFC inclusion year. 

(c) [Reserved] 

[T.D. 9866, 84 FR 29341, June 21, 2019]