Irc Section 952

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Irc section 952. 99 514 set out as an effective date note under section 846 of this title. 952 a 3 a ii is described in subsection b multiplied by. 1841 c without regard to subparagrap hs c and g of 12 u s c.

Internal revenue code 952. If the subpart f income as defined in section 952 a of a controlled foreign corporation exceeds the foreign corporation s earnings and profits for the taxable year the subpart f income includible in the income of the corporation s united states shareholders is reduced under section 952 c 1 a in accordance with the following rules. Subpart f income defined on westlaw.

Or 2 a corporation not described in 1 above that is more than 80 owned directly or indirectly by vote or value by a bank holding company. 954 a 2. For more detailed codes research information including annotations and citations please visit westlaw.

952 a 3 a i is attributable to earnings and profits of the foreign corporation included in the gross income of a united states person under section 951 other than by reason of this paragraph or i r c. For purposes of this title the term united states shareholder means with respect to any foreign corporation a united states person as defined in section 957 c who owns within the meaning of section 958 a or is considered as owning by applying the rules of ownership of section 958 b 10 percent or more of the total combined voting power of all classes of stock entitled to vote. 954 a 1 the foreign personal holding company income for the taxable year determined under subsection c and reduced as provided in subsection b 5 i r c.

For purposes of section 952 a 2 the term foreign base company income means for any taxable year the sum of i r c. For purposes of applying section 952 c 1 a of the 1986 code the earnings and profits of any corporation shall be determined without regard to any increase in earnings and profits under section 1023 e 3 c of the reform act pub.