Code Section 954(c)(6)
| Code Section | Effective Date | Name of Act | Name of Provision |
|---|---|---|---|
| 954(c)(6) | * 12/31/2009 | The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 | Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules |
* Notes on Effective Date
The provision is effective for taxable years of foreign corporations beginning after December 31, 2009, and for taxable years of U.S. shareholders with or within which such taxable years of such foreign corporations end.
Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules
Explanation of Provision
The provision extends for two years the application of the look thru rule, to taxable years of foreign corporations beginning before January 1, 2012, and for taxable years of U.S. shareholders with or within which such taxable years of such foreign corporations end.
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