26 C.F.R. § 1.959-4 Distributions to United States persons not counting as dividends.
Title 26 - Internal Revenue
Except as provided in section 960(a)(3) and §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 §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 §1.956–1, relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property. [T.D. 7120, 36 FR 10860, June 4, 1971]
Title 26: Internal Revenue
PART 1—INCOME TAXES
controlled foreign corporations
§ 1.959-4 Distributions to United States persons not counting as dividends.
