Treas. Reg. § 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).

eCFR as of 2026-10-19 · Interprets § 956 · Temporary, issued Nov. 3, 2016: § 7805(e) 3-year limit

(a)-(e)(4) [Reserved]

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    (5) Exclusion for certain recourse obligations. For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (f) of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.

    (e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).

    (f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.

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      (g)-(h) [Reserved]

      [T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]