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income without the approval or consent of any adverse
party is, or, in the discretion of the grantor or a
nonadverse party, or both, may be--
(1) distributed to the grantor or the
grantor’s spouse;
(2) held or accumulated for future
distribution to the grantor or the grantor’s
spouse; or
(3) applied to the payment of premiums
on policies of insurance on the life of the
grantor or the grantor’s spouse (except
policies of insurance irrevocably payable for
a purpose specified in section 170(c)
(relating to definition of charitable
contributions)).
This subsection shall not apply to a power the exercise
of which can only affect the beneficial enjoyment of
the income for a period commencing after the occurrence
of an event such that the grantor would not be treated
as the owner under section 673 if the power were a
reversionary interest; but the grantor may be treated
as the owner after the occurrence of the event unless
the power is relinquished.
* * * * * * *
SEC. 951. AMOUNTS INCLUDED IN GROSS INCOME OF UNITED
STATES SHAREHOLDERS.
(a) Amounts Included.--
(1) In general.--If a foreign
corporation is a controlled foreign
corporation for an uninterrupted period of 30
days or more during any taxable year, every
person who is a United States shareholder (as
defined in subsection (b)) of such
corporation and who owns (within the meaning
of section 958(a)) stock in such corporation
on the last day, in such year, on which such
corporation is a controlled foreign
corporation shall include in his gross
income, for his taxable year in which or with
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