Section 956 Investments in U.S. Property

This flowchart deals with the investment in U.S. property rules under section 956 that can trigger deemed income inclusions to U.S. shareholders of controlled foreign corporations. The flowchart covers U.S. tangible and intangible property, stock in domestic corporations, obligations of U.S. persons, stock pledges, guarantees, zero basis rules, and more.

 

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