[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: 26CFR1.555-1]

[Page 289]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.555-1  General rule.

    The gross income of a foreign corporation which is a foreign 
personal holding company is computed the same as if the foreign 
corporation were a domestic corporation which is a personal holding 
company. See section 542(a)(1) and Sec. 1.542-2. The gross income of a 
foreign personal holding company thus includes income from all sources, 
whether within or without the United States, which is not specifically 
excluded from gross income under any other provisions of the Code. For 
example, the gross income of a foreign personal holding company includes 
all income from sources outside the United States even though the 
foreign personal holding company is a foreign corporation not engaged in 
trade or business within the United States. However, the gross income of 
a foreign corporation which is a foreign personal holding company shall 
not include, with respect to a United States shareholder described in 
section 951(b), dividends received by such corporation which are 
excluded under section 959(b) from the income of such corporation with 
respect to such shareholder.

[T.D. 6500, 25 FR 11737, Nov. 26, 1960, as amended by T.D. 6795, 30 FR 
934, Jan. 29, 1965]