Time and manner of election.

(i) Time and manner of election. For a foreign corporation's first taxable year that ends with or within a taxable year of a United States shareholder of the foreign corporation ending on or after November 2, 2020 in which the foreign corporation has a foreign tax redetermination (the first redetermination year), the controlling domestic shareholders (as defined in 1.964-1(c)(5)) of the foreign corporation make the election described in paragraph (e)(1) of this section by -

Source

26 CFR § 1.905-5


Scoping language

None
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