§955 — Repealed. Pub. L. 115–97, title I, § 14212(a), Dec. 22, 2017, 131 Stat. 2217]
15 cases·15 cited
Statute Text — 26 U.S.C. §955
[§ 955. Repealed. Pub. L. 115–97, title I, § 14212(a), Dec. 22, 2017, 131 Stat. 2217] Section, added Pub. L. 94–12, title VI, § 602(d)(3)(A), Mar. 29, 1975, 89 Stat. 62; amended Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834; Pub. L. 99–514, title XII, § 1221(c)(3)(B), (C), Oct. 22, 1986, 100 Stat. 2553; Pub. L. 100–647, title I, § 1012(i)(11), Nov. 10, 1988, 102 Stat. 3509, related to withdrawal of previously excluded subpart F income from qualified investment. A prior section 955, added Pub. L. 87–834, § 12(a), Oct. 16, 1962, 76 Stat. 1013, related to investments in less developed countries and dealing with less developed country corporations, prior to repeal by Pub. L. 94–12, title VI, § 602(c)(5), Mar. 29, 1975, 89 Stat. 59. Statutory Notes and Related Subsidiaries Effective Date of RepealRepeal applicable to taxable years of foreign corporations beginning after Dec. 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 14212(c) of Pub. L. 115–97, set out as an Effective Date of 2017 Amendment note under section 851 of this title.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.955-0 Effective dates
- Treas. Reg. §Treas. Reg. §1.955-0(a) Section 955 as in effect before the enactment of the Tax Reduction Act of 1975—(1) In general.
- Treas. Reg. §Treas. Reg. §1.955-0(b) Section 955 as amended by the Tax Reduction Act of 1975.
- Treas. Reg. §Treas. Reg. §1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries
- Treas. Reg. §Treas. Reg. §1.955-1(a) §1.955-1(a)
- Treas. Reg. §Treas. Reg. §1.955-1(b) §1.955-1(b)
- Treas. Reg. §Treas. Reg. §1.955-1(c) Shareholder's pro rata share of amount withdrawn by controlled foreign corporation—(1) In general.
- Treas. Reg. §Treas. Reg. §1.955-1(d) Illustrations.
- Treas. Reg. §Treas. Reg. §1.955-1(i) §1.955-1(i)
- Treas. Reg. §Treas. Reg. §1.955-2 Amount of a controlled foreign corporation's qualified investments in less developed countries
- Treas. Reg. §Treas. Reg. §1.955-2(a) Included property.
- Treas. Reg. §Treas. Reg. §1.955-2(b) Special rules—(1) Excluded property.
- Treas. Reg. §Treas. Reg. §1.955-2(c) Termination of designation as a less developed country.
- Treas. Reg. §Treas. Reg. §1.955-2(d) Amount attributable to property—(1) General rule.
- Treas. Reg. §Treas. Reg. §1.955-2(i) §1.955-2(i)
- Treas. Reg. §Treas. Reg. §1.955-3 Election as to date of determining qualified investments in less developed countries
- Treas. Reg. §Treas. Reg. §1.955-3(a) Nature of election.
- Treas. Reg. §Treas. Reg. §1.955-3(b) Time and manner of making election—(1) Without consent.
- Treas. Reg. §Treas. Reg. §1.955-3(c) Effect of election—(1) General.
- Treas. Reg. §Treas. Reg. §1.955-3(d) Illustrations.
- Treas. Reg. §Treas. Reg. §1.955-3(i) §1.955-3(i)
- Treas. Reg. §Treas. Reg. §1.955-3(v) The sum of the amounts excluded under section 954(b)(1) and paragraph (b)(1) of § 1.
- Treas. Reg. §Treas. Reg. §1.955-4 Definition of less developed country
- Treas. Reg. §Treas. Reg. §1.955-4(a) Designation by Executive order.
- Treas. Reg. §Treas. Reg. §1.955-4(b) Countries not eligible for designation.
15 Citing Cases
- 17 - close of any taxable year is the aggregate amount of such property held, directly or indirectly, by the controlled foreign corporation at the close of the taxable year, to the extent such amount would have constituted a dividend (determined after the application of section 955(a)) if it had been distributed.
nings of a controlled foreign corporation invested in United States property at the close of any taxable year is the aggregate amount of such property held, directly or indirectly, by the controlled foreign corporation at the close of the taxable year, to the extent such amount would have constituted a dividend (determined after the application of section 955(a)) if it had been distributed.