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  3. Subpart F—Controlled Foreign Corporations (§§ 9...


Subpart F—Controlled Foreign Corporations (§§ 951 – 965)


  • § 951. Amounts included in gross income of United States shareholders
  • § 951A. Global intangible low-taxed income included in gross income of United States shareholders
  • § 952. Subpart F income defined
  • § 953. Insurance income
  • § 954. Foreign base company income
  • [§ 955. Repealed. Pub. L. 115–97, title I, § 14212(a), Dec. 22, 2017, 131 Stat. 2217]
  • § 956. Investment of earnings in United States property
  • [§ 956A. Repealed. Pub. L. 104–188, title I, § 1501(a)(2), Aug. 20, 1996, 110 Stat. 1825]
  • § 957. Controlled foreign corporations; United States persons
  • § 958. Rules for determining stock ownership
  • § 959. Exclusion from gross income of previously taxed earnings and profits
  • § 960. Deemed paid credit for subpart F inclusions
  • § 961. Adjustments to basis of stock in controlled foreign corporations and of other property
  • § 962. Election by individuals to be subject to tax at corporate rates
  • [§ 963. Repealed. Pub. L. 94–12, title VI, § 602(a)(1), Mar. 29, 1975, 89 Stat. 58]
  • § 964. Miscellaneous provisions
  • § 965. Treatment of deferred foreign income upon transition to participation exemption system of taxation
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