[Code of Federal Regulations]
[Title 26, Volume 10]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.959-4]

[Page 382]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.959-4  Distributions to United States persons not counting as 
dividends.

    Except as provided in section 960(a)(3) and Sec. 1.960-2, any 
distribution to a United States person which is excluded from the gross 
income of such person under section 959(a)(1) and Sec. 1.959-1 shall be 
treated for purposes of chapter 1 (relating to normal taxes and 
surtaxes) of subtitle A (relating to income taxes) of the Code as a 
distribution which is not a dividend. However, see paragraph (b)(1) of 
Sec. 1.956-1, relating to the dividend limitation on the amount of a 
controlled foreign corporation's investment of earnings in United States 
property.

[T.D. 7120, 36 FR 10860, June 4, 1971]