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26 U.S.C. § 957 — Controlled foreign corporations; United States persons
Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** For purposes of this title, the term “controlled foreign corporation” means any foreign corporation if more than 50 percent of—
(1) the total combined voting power of all classes of stock of such corporation entitled to vote, or
(2) the total value of the stock of such corporation,
is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such foreign corporation.
**(b) Special rule for insurance** For purposes only of taking into account income described in section 953(a) (relating to insurance income), the term “controlled foreign corporation” includes not only a foreign corporation as defined by subsection (a) but also one of which more than 25 percent of the total combined voting power of all classes of stock (or more than 25 percent of the total value of stock) is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such corporation, if the gross amount of premiums or other consideration in respect of the reinsurance or the issuing of insurance or annuity contracts not described in section 953(e)(2) exceeds 75 percent of the gross amount of all premiums or other consideration in respect of all risks.
**(c) United States person** For purposes of this subpart, the term “United States person” has the meaning assigned to it by section 7701(a)(30) except that—
(1) with respect to a corporation organized under the laws of the Commonwealth of Puerto Rico, such term does not include an individual who is a bona fide resident of Puerto Rico, if a dividend received by such in
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Source file: Laws/federal/codes/united-states-code/title-26/section-957-controlled-foreign-corporations-united-states-persons--c90e2a09b6.md
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Source location: Title 26, Chapter 1, § 957; chapter-001-normal-taxes-and-surtaxes.md
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**(a) General rule** For purposes of this title, the term “controlled foreign corporation” means any foreign corporation if more than 50 percent of—
(1) the total combined voting power of all classes of stock of such corporation entitled to vote, or
(2) the total value of the stock of such corporation,
is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such foreign corporation.
**(b) Special rule for insurance** For purposes only of taking into account income described in section 953(a) (relating to insurance income), the term “controlled foreign corporation” includes not only a foreign corporation as defined by subsection (a) but also one of which more than 25 percent of the total combined voting power of all classes of stock (or more than 25 percent of the total value of stock) is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such corporation, if the gross amount of premiums or other consideration in respect of the reinsurance or the issuing of insurance or annuity contracts not described in section 953(e)(2) exceeds 75 percent of the gross amount of all premiums or other consideration in respect of all risks.
**(c) United States person** For purposes of this subpart, the term “United States person” has the meaning assigned to it by section 7701(a)(30) except that—
(1) with respect to a corporation organized under the laws of the Commonwealth of Puerto Rico, such term does not include an individual who is a bona fide resident of Puerto Rico, if a dividend received by such individual during the taxable year from such corporation would, for purposes of section 933(1), be treated as income derived from sources within Puerto Rico, and
(2) with respect to a corporation organized under the laws of Guam, American Samoa, or the Northern Mariana Islands—
(A) 80 percent or more of the gross income of which for the 3-year period ending at the close of the taxable year (or for such part of such period as such corporation or any predecessor has been in existence) was derived from sources within such a possession or was effectively connected with the conduct of a trade or business in such a possession, and
(B) 50 percent or more of the gross income of which for such period (or part) was derived from the active conduct of a trade or business within such a possession,
such term does not include an individual who is a bona fide resident of Guam, American Samoa, or the Northern Mariana Islands.
For purposes of subparagraphs (A) and (B) of paragraph (2), the determination as to whether income was derived from the active conduct of a trade or business within a possession shall be made under regulations prescribed by the Secretary.
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Federal law — U.S. Code and appendices · legal_authorities
The proceeds of customs duties, the proceeds of the United States income tax, the proceeds of any taxes levied by the Congress on the inhabitants of the Virgin Islands, and the proceeds of all quarantine, passport, immigration, and naturalization fees collected in the Virgin Islands, (less the cost of collecting such duties, taxes and fees as may be directly attributable (as certified by the Comptroller of the Virgin Islands) to the importation of petroleum products until January 1, 1982: Provided, That any other retained costs not heretofore remitted pursuant to the Act of August 18, 1978, shall be immediately remitted to the Treasury of the Virgin Islands notwithstanding any other provision of law) shall be covered into the treasury of the Virgin Islands, and shall be available for expenditure as the Legislature of the Virgin Islands may provide: Provided, That the term “inhabitants of the Virgin Islands” as used in this section shall include all persons whose permanent residence is in the Virgin Islands, and such persons shall satisfy their income tax obligations under applicable taxing statutes of the United States by paying their tax on income derived from all sources both within and outside the Virgin Islands into the treasury of the Virgin Islands: Provided further, That nothing in this chapter shall be construed to apply to any tax specified in section 3811 of the Internal Revenue Code.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Foreign base company income** For purposes of section 952(a)(2), the term “foreign base company income” means for any taxable year the sum of—
(1) the foreign personal holding company income for the taxable year (determined under subsection (c) and reduced as provided in subsection (b)(5)),
(2) the foreign base company sales income for the taxable year (determined under subsection (d) and reduced as provided in subsection (b)(5)), and
(3) the foreign base company services income for the taxable year (determined under subsection (e) and reduced as provided in subsection (b)(5)).
**(b) Exclusion and special rules**
(1) **Repealed. Pub. L. 94–12, title VI, § 602(c)(1), Mar. 29, 1975, 89 Stat. 58]**
(2) **Repealed. Pub. L. 99–514, title XII, § 1221(c)(1), Oct. 22, 1986, 100 Stat. 2553]**
(3) **De minimis, etc., rules** — For purposes of subsection (a) and section 953—
(A) *De minimis rule* — If the sum of foreign base company income (determined without regard to paragraph (5)) and the gross insurance income for the taxable year is less than the lesser of—
(i) 5 percent of gross income, or
(ii) $1,000,000,
no part of the gross income for the taxable year shall be treated as foreign base company income or insurance income.
(B) *Foreign base company income and insurance income in excess of 70 percent of gross income* — If the sum of the foreign base company income (determined without regard to paragraph (5)) and the gross insurance income for the taxable year exceeds 70 percent of gross income, the entire gross income for the taxable year shall, subject to the provisions of paragraphs (4) and (5), be treated as foreign base company income or insurance income (whichever is appropriate).
(C) *Gross insurance income* — For purposes of subparagr
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 954
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Bona fide resident** For purposes of this subpart, section 865(g)(3), section 876, section 881(b), paragraphs (2) and (3) of section 901(b), section 957(c), section 3401(a)(8)(C), and section 7654(a), except as provided in regulations, the term “bona fide resident” means a person—
(1) who is present for at least 183 days during the taxable year in Guam, American Samoa, the Northern Mariana Islands, Puerto Rico, or the Virgin Islands, as the case may be, and
(2) who does not have a tax home (determined under the principles of section 911(d)(3) without regard to the second sentence thereof) outside such specified possession during the taxable year and does not have a closer connection (determined under the principles of section 7701(b)(3)(B)(ii)) to the United States or a foreign country than to such specified possession.
For purposes of paragraph (1), the determination as to whether a person is present for any day shall be made under the principles of section 7701(b).
**(b) Source rules** Except as provided in regulations, for purposes of this title—
(1) except as provided in paragraph (2), rules similar to the rules for determining whether income is income from sources within the United States or is effectively connected with the conduct of a trade or business within the United States shall apply for purposes of determining whether income is from sources within a possession specified in subsection (a)(1) or effectively connected with the conduct of a trade or business within any such possession, and
(2) any income treated as income from sources within the United States or as effectively connected with the conduct of a trade or business within the United States shall not be treated as income from sources within any such possession or as effectively connected w
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 937
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** In the case of an individual who is a bona fide resident of a specified possession during the entire taxable year, gross income shall not include—
(1) income derived from sources within any specified possession, and
(2) income effectively connected with the conduct of a trade or business by such individual within any specified possession.
**(b) Deductions, etc. allocable to excluded amounts not allowable** An individual shall not be allowed—
(1) as a deduction from gross income any deductions (other than the deduction under section 151, relating to personal exemptions), or
(2) any credit,
properly allocable or chargeable against amounts excluded from gross income under this section.
**(c) Specified possession** For purposes of this section, the term “specified possession” means Guam, American Samoa, and the Northern Mariana Islands.
**(d) Employees of the United States** Amounts paid for services performed as an employee of the United States (or any agency thereof) shall be treated as not described in paragraph (1) or (2) of subsection (a).
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 931
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Federal law — U.S. Code and appendices · legal_authorities
Page 2200
TITLE 26—INTERNAL REVENUE CODE
[§ 956A
Subsec. (c)(2). Pub. L. 105–34, § 1173(a), added subpars.
(J) and (K) and concluding provisions.
1996—Subsec. (b)(1). Pub. L. 104–188, § 1501(b)(2), reen-
acted heading without change and amended text gen-
erally. Prior to amendment, text read as follows: ‘‘For
purposes of this section, the term ‘applicable earnings’
has the meaning given to such term by section 956A(b),
except that the provisions of such section excluding
earnings and profits accumulated in taxable years be-
ginning before October 1, 1993, shall be disregarded.’’
Subsec. (b)(3). Pub. L. 104–188, § 1501(b)(3), reenacted
heading without change and amended text generally.
Prior to amendment, text read as follows: ‘‘Rules simi-
lar to the rules of section 956A(e) shall apply for pur-
poses of this section.’’
1993—Subsec. (a). Pub. L. 103–66, § 13232(a)(2), added
subsec. (a) and struck out former subsec. (a) which con-
sisted of introductory provisions and pars. (1) to (3) set-
ting out general rules for calculating amount of earn-
ings of a controlled foreign corporation invested in
United States and pro rata share of the increase for any
taxable year in earnings of such a corporation invested
in United States property.
Subsecs. (b) to (d). Pub. L. 103–66, § 13232(a), added
subsec. (b) and redesignated former subsecs. (b) and (c)
as (c) and (d), respectively.
Subsec. (e). Pub. L. 103–66, § 13232(b), added subsec. (e).
1986—Subsec. (b)(3)(A). Pub. L. 99–514 inserted ‘‘(other
than subparagraph (H) thereof)’’.
1984—Subsec. (b)(2)(I). Pub. L. 98–369, § 801(d)(8), added
subpar. (I).
Subsec. (b)(3). Pub. L. 98–369, § 123(b), added par. (3).
1976—Subsec. (b)(2)(F) to (H). Pub. L. 94–455, § 1021(a),
added subpars. (F) and (G) and redesignated
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 957
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