Coordination of subpart F with election of a foreign investment company to distribute income.

[Title 26 CFR 1.951-2]
[Code of Federal Regulations (annual edition) - April 1, 2002 Edition]
[Title 26 - INTERNAL REVENUE]
[Chapter I - INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY]
[Subchapter A - INCOME TAX (CONTINUED)]
[Part 1 - INCOME TAXES]
[Sec. 1.951-2 - Coordination of subpart F with election of a foreign investment company to distribute income.]
[From the U.S. Government Printing Office]


26INTERNAL REVENUE102002-04-012002-04-01falseCoordination of subpart F with election of a foreign investment company to distribute income.1.951-2Sec. 1.951-2INTERNAL REVENUEINTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURYINCOME TAX (CONTINUED)INCOME TAXES
Sec. 1.951-2  Coordination of subpart F with election of a foreign investment company to distribute income.

    A United States shareholder who for his taxable year is a qualified 
shareholder (within the meaning of section 1247(c)) of a foreign 
investment company with respect to which an election under section 
1247(a) and the regulations thereunder is in effect for the taxable year 
of such company which ends with or within such taxable year of such 
shareholder shall not be required to include any amount in his gross 
income for his taxable year under paragraph (a) of Sec. 1.951-1 with 
respect to such company for that taxable year of such company.

[T.D. 6795, 30 FR 937, Jan. 29, 1965]