Sec. 1.959-4 Distributions to United States persons not counting as dividends.

Except as provided in section 960(a)(3) and section 1.960-2, any distribution to a United States person which is excluded from the gross income of such person under section 959(a)(1) and section 1.959-1 shall be treated for purposes of Chapter 1 (relating to normal taxes and surtaxes) of Subtitle A (relating to income taxes) of the Code as a distribution which is not a dividend. However, see paragraph (b)(1) of section 1.956-1, relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property.