26 C.F.R. § 1.964-5 Effective date of subpart F.
Title 26 - Internal Revenue
Sections 951 through 964 and §§1.951 through 1.964–4 shall apply with respect to taxable years of foreign corporations beginning after December 31, 1962, and to taxable years of United States shareholders within which or with which such taxable years of such corporations end. [T.D. 7120, 36 FR 10862, June 4, 1971
Title 26: Internal Revenue
PART 1—INCOME TAXES
controlled foreign corporations
§ 1.964-5 Effective date of subpart F.
