republic-os/legal/us/code/title-26/chapter-1/section-951b.md

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LegalText	26 U.S.C. § 951B	Amounts included in gross income of foreign controlled United States shareholders	us	united_states_code	code_section	26	INTERNAL REVENUE CODE	1	NORMAL TAXES AND SURTAXES	951B	26 U.S.C. § 951B	current	119-100	2026-06-26	official	https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip	/us/usc/t26/s951B	data/legal/raw/us/code/title-26/usc26.xml	f9c477a31334ea89d8ef6b6ec65ba0e0688229d612d74810f0ca33a8336180e5	a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4	a6f8b7ba9171a6165d4fe6f3aa8731f1f2dbfbab1d693a56c3841cd4b4765828	2026-07-04	official	legal us-code

26 U.S.C. § 951B - Amounts included in gross income of foreign controlled United States shareholders

Text

(a) In general In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation—

(1) this subpart (other than sections 951A, 951(b), and 957) shall be applied with respect to such shareholder (separately from, and in addition to, the application of this subpart without regard to this section)—

(A) by substituting “foreign controlled United States shareholder” for “United States shareholder” each place it appears therein, and

(B) by substituting “foreign controlled foreign corporation” for “controlled foreign corporation” each place it appears therein, and

(2) section 951A (and such other provisions of this subpart as provided by the Secretary) shall be applied with respect to such shareholder—

(A) by treating each reference to “United States shareholder” in such section as including a reference to such shareholder, and

(B) by treating each reference to “controlled foreign corporation” in such section as including a reference to such foreign controlled foreign corporation.

(b) Foreign controlled United States shareholder For purposes of this section, the term “foreign controlled United States shareholder” means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if—

(1) section 951(b) were applied by substituting “more than 50 percent” for “10 percent or more”, and

(2) section 958(b) were applied without regard to paragraph (4) thereof.

(c) Foreign controlled foreign corporation For purposes of this section, the term “foreign controlled foreign corporation” means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section 957(a) were applied—

(1) by substituting “foreign controlled United States shareholders” for “United States shareholders”, and

(2) by substituting “section 958(b) (other than paragraph (4) thereof)” for “section 958(b)”.

(d) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance—

(1) to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart (including any reporting requirement), and

(2) with respect to the treatment of foreign controlled foreign corporations that are passive foreign investment companies (as defined in section 1297).

(Added Pub. L. 119–21, title VII, § 70353(b), July 4, 2025, 139 Stat. 209.)

Notes

Statutory Notes and Related Subsidiaries

Effective DatePub. L. 119–21, title VII, § 70353(d), July 4, 2025, 139 Stat. 210, provided that: “The amendments made by this section [enacting this section and amending section 958 of this title] shall apply to taxable years of foreign corporations beginning after December 31, 2025.”

ConstructionPub. L. 119–21, title VII, § 70353(f), July 4, 2025, 139 Stat. 210, provided that: “The amendments made by this section [enacting this section and amending section 958 of this title] shall not be construed to create any inference with respect to the proper application of any provision of the Internal Revenue Code of 1986 with respect to taxable years beginning before the taxable years to which such amendments apply.”

Special RulePub. L. 119–21, title VII, § 70353(e), July 4, 2025, 139 Stat. 210, provided that: “(1) In general.—Except to the extent provided by the Secretary of the Treasury (or the Secretary’s delegate), the effective date of any amendment to the Internal Revenue Code of 1986 shall be applied by treating references to United States shareholders as including references to foreign controlled United States shareholders, and by treating references to controlled foreign corporations as including references to foreign controlled foreign corporations. “(2) Definitions.—Any term used in paragraph (1) which is used in subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 (as amended by this section) shall have the meaning given such term in such subpart.”