Controlled Foreign Corporations

  1. Law
  2. USC 26
  3. Internal Revenue Code
  4. Income Taxes
  5. NORMAL TAXES AND SURTAXES
  6. Tax Based on Income From Sources Within or Without the United States
  7. INCOME FROM SOURCES WITHOUT THE UNITED STATES
  8. Controlled Foreign Corporations

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Section
951

Amounts included in gross income of United States shareholders

Section
951A

Global intangible low-taxed income included in gross income of United States shareholders

Section
952

Subpart F income defined

Section
953

Insurance income

Section
954

Foreign base company income

Section
956

Investment of earnings in United States property

Section
957

Controlled foreign corporations; United States persons

Section
958

Rules for determining stock ownership

Section
959

Exclusion from gross income of previously taxed earnings and profits

Section
960

Deemed paid credit for subpart F inclusions

Section
961

Adjustments to basis of stock in controlled foreign corporations and of other property

Section
962

Election by individuals to be subject to tax at corporate rates

Section
964

Miscellaneous provisions

Section
965

Treatment of deferred foreign income upon transition to participation exemption system of taxation