[Code of Federal Regulations]
[Title 26, Volume 7]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.551-1]

[Page 283-284]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.551-1  General rule.

    Part III (section 551 and following), subchapter G, chapter 1 of the 
Code, does not impose a tax on foreign personal holding companies. The 
undistributed foreign personal holding company income of such companies, 
however, must be included in the manner and to the extent set forth in 
section 551, in the gross income of their United States shareholders, 
that is, the shareholders who are individual citizens or

[[Page 284]]

residents of the United States, domestic corporations, domestic 
partnerships, and estates or trusts other than estates or trusts the 
gross income of which under subtitle A of the Code includes only income 
from sources within the United States.