- 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. (2) Pro rata share of increase for year. * * * * * * * * * * (b) United States property defined.-- (1) In general.--For purposes of subsection (a), the term “United States property” means any property acquired after December 31, 1962, which is-- (A) tangible property located in the United States; (B) stock of a domestic corporation; (C) an obligation of a United States person; or (D) any right to the use in the United States of-- (i) a patent or copyright, (ii) an invention, model, or design (whether or not patented), (iii) a secret formula or process, or (iv) any other similar right, which is acquired or developed by the controlled foreign corporation for use in the United States. (2) Exceptions.--For purposes of subsection (a), the term “United States property” does not include-- (A) obligations of the United States, money, or deposits with persons carrying on the banking business;Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011