# 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).

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-1.956-1T>. Interprets 26 U.S.C. § 956.

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

(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. 

(g)-(h) [Reserved] 

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