TITLE 26. INTERNAL REVENUE CODE § 951. Amounts included in gross income of United States shareholders., 26 USCS § 951

Summary

(a) Amounts included.

(1) In general. If a foreign corporation is a controlled foreign corporation at any time during any taxable year, every person who is a United States shareholder (as defined in subsection (b)) of such corporation and who owns (within the meaning of section 958(a) [26 USCS § 958(a)]) stock in such corporation on the last day, in such year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends—

(A) his pro rata share (determined under paragraph (2)) of the corporation’s subpart F income for such year, and

(B) the amount determined under section 956 [26 USCS § 956] with respect to such shareholder for such year (but only to the extent not excluded from gross income under section 959(a)(2) [26 USCS § 959(a)(2)]).

(2) Pro rata share of subpart F income. The pro rata share referred to in paragraph (1)(A)(i) in the case of any United States shareholder ...