26 CFR § 1.954-5 - Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.

---
identifier: "/us/cfr/t26/s1.954-5"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 1.954-5 - Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976."
title_number: 26
title_name: "Internal Revenue"
section_number: "1.954-5"
section_name: "Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "A"
subchapter_name: "INCOME TAX"
part_number: "1"
part_name: "INCOME TAXES"
positive_law: false
currency: "2026-04-05"
last_updated: "2026-04-05"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805, unless otherwise noted."
regulatory_source: "T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 21, 1960; T.D. 9989, 89 FR 17606, Mar. 11, 2024, unless otherwise noted."
cfr_part: "1"
---


# 1.954-5 Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.

For rules applicable to taxable years of controlled foreign corporations beginning before January 1, 1976, see section 954(b)(1) (as in effect before the enactment of the Tax Reduction Act of 1975) and 26 CFR 1.954-5 (Revised as of April 1, 1975).

[T.D. 7893, 48 FR 22508, May 19, 1983]