26 CFR § 1.956-1T - Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).

---
identifier: "/us/cfr/t26/s1.956-1T"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 1.956-1T - Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary)."
title_number: 26
title_name: "Internal Revenue"
section_number: "1.956-1T"
section_name: "Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary)."
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"
---


# 1.956-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).

(a)-(e)(4) [Reserved]

(5) *Exclusion for certain recourse obligations.* For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (f) of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.

(e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).

(f) *Effective/applicability date.* Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.

(g)-(h) [Reserved]

[T.D. 9792, 81 FR 76507, Nov. 3, 2016; 81 FR 95471, Dec. 28, 2016]