Sec. 1.956-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
(a) through (e)(4) [Reserved]
(e)(5) Exclusion for certain recourse obligations.
For purposes of §1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (e) of §1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.
(e)(6) [Reserved].
For further guidance, see §1.956-1(e)(6).
(f) Effective/applicability date.
Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
(g) - (h) [Reserved]
[T.D. 8209, 53 FR 22171, June 14, 1988, as amended by T.D. 9402, 73 FR 35580-35583, June 24, 2008; T.D. 9530, 76 FR 36993-36995, June 24, 2011; T.D. 9733, 80 FR 52976-52982, Sept. 2, 2015; corrected by 80 F.R. 66415-66416, Oct. 29, 2015. Revised by T.D. 9792, 81 FR 76497-76512, Nov. 3, 2016; corrected at 81 F.R. 95471-95472, Dec. 28, 2016.]
