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26 U.S.C. § 951B — Amounts included in gross income of foreign controlled United States shareholders
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation—
(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
(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.
**(b) Foreign controlled United States shareholder** For purposes of this section, the term “foreign controlled United States shareholder” means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if—
(1) section 951(b) were applied by substituting “more than 50 percent” for “10 percent or more”, and
(2) section 958(b) were applied without regard to paragraph (4) thereof.
**(c) Foreign controlled foreign corporation** For purposes of this section, the term “foreign controlled foreign corporation” means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section 957(a) were ap
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Source file: Laws/federal/codes/united-states-code/title-26/section-951b-amounts-included-in-gross-income-of-foreign-controlled-united-states-sha--0b928f9502.md
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Source location: Title 26, Chapter 1, § 951B; chapter-001-normal-taxes-and-surtaxes.md
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**(a) In general** In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation—
(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
(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.
**(b) Foreign controlled United States shareholder** For purposes of this section, the term “foreign controlled United States shareholder” means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if—
(1) section 951(b) were applied by substituting “more than 50 percent” for “10 percent or more”, and
(2) section 958(b) were applied without regard to paragraph (4) thereof.
**(c) Foreign controlled foreign corporation** For purposes of this section, the term “foreign controlled foreign corporation” means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section 957(a) were applied—
(1) by substituting “foreign controlled United States shareholders” for “United States shareholders”, and
(2) by substituting “section 958(b) (other than paragraph (4) thereof)” for “section 958(b)”.
**(d) Regulations** The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance—
(1) to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart (including any reporting requirement), and
(2) with respect to the treatment of foreign controlled foreign corporations that are passive foreign investment companies (as defined in section 1297).
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Direct and indirect ownership**
(1) **General rule** — For purposes of this subpart (other than section 960), stock owned means—
(A) stock owned directly, and
(B) stock owned with the application of paragraph (2).
(2) **Stock ownership through foreign entities** — For purposes of subparagraph (B) of paragraph (1), stock owned, directly or indirectly, by or for a foreign corporation, foreign partnership, or foreign trust or foreign estate (within the meaning of section 7701(a)(31)) shall be considered as being owned proportionately by its shareholders, partners, or beneficiaries. Stock considered to be owned by a person by reason of the application of the preceding sentence shall, for purposes of applying such sentence, be treated as actually owned by such person.
(3) **Special rule for mutual insurance companies** — For purposes of applying paragraph (1) in the case of a foreign mutual insurance company, the term “stock” shall include any certificate entitling the holder to voting power in the corporation.
**(b) Constructive ownership** For purposes of sections 951(b), 954(d)(3), 956(c)(2), and 957, section 318(a) (relating to constructive ownership of stock) shall apply to the extent that the effect is to treat any United States person as a United States shareholder within the meaning of section 951(b), to treat a person as a related person within the meaning of section 954(d)(3), to treat the stock of a domestic corporation as owned by a United States shareholder of the controlled foreign corporation for purposes of section 956(c)(2), or to treat a foreign corporation as a controlled foreign corporation under section 957, except that—
(1) In applying paragraph (1)(A) of section 318(a), stock owned by a nonresident alien individual (other than a foreig
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 958
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