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income withdrawn (as determined
under section 955(a)(3)) for the
taxable year, as
(B) the part of such year
during which the corporation is a
controlled foreign corporation
bears to the entire year.
(4) Limitation on pro rata share of
investment in United States property.- For
purposes of paragraph (1)(B), the pro rata
share of any United States shareholder in the
increase of the earnings of a controlled
foreign corporation invested in United States
property shall not exceed an amount (A) which
bears the same ratio to his pro rata share of
such increase (as determined under section
956(a)(2)) for the taxable year, as (B) the
part of such year during which the
corporation is a controlled foreign
corporation bears to the entire year.
(b) United States Shareholder Defined.--For
purposes of this subpart, 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 of such foreign corporation.
* * * * * * *
SEC. 958. RULES FOR DETERMINING STOCK OWNERSHIP.
(a) Direct and Indirect Ownership.--
(1) General rule.--For purposes of this
subpart (other than sections 955(b)(1)(A) and
(B), 955(c)(2)(A)(ii), and 960(a)(1)), stock
owned means
(A) stock owned directly, and
(B) stock owned with the
application of paragraph (2).
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