# Treas. Reg. § 1.954(c)(6)-1: Certain cases in which section 954(c)(6) exception not available.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-1.954(c)(6)-1>. Interprets 26 U.S.C. § 954.

(a) Cross-references to other rules. For a non-exclusive list of rules that in certain cases limit the applicability of the exception to foreign personal holding company income under section 954(c)(6), see— 

(1) Section 1.245A-5(d) (rules regarding the application of section 954(c)(6) to extraordinary disposition amounts); 

(2) Section 1.245A-5(f) (rules regarding the application of section 954(c)(6) to tiered extraordinary reduction amounts); 

(3) Section 1.245A(e)-1(c) (rules regarding tiered hybrid dividends); 

(4) Section 1.367(b)-4(e)(4) (rules regarding income inclusion and gain recognition in certain exchanges following an inversion transaction); 

(5) Section 964(e)(4)(A) (rules regarding certain gain from the sale or exchange of stock that is recharacterized as a dividend); and 

(6) Section 1.7701(l)-4(e) (rules regarding recharacterization of certain transactions following an inversion transaction). 

(b) Applicability date. This section applies as of August 27, 2020. 

[T.D. 9909, 85 FR 53097, Aug. 27, 2020]