(ii) Recapture. Each recapture account of the controlled foreign corporation will be recharacterized, on a proportionate basis, as subpart F income in the same separate category (as defined in 1.904-5(a)(4)(v)) as the recapture account to the extent that current year earnings and profits exceed subpart F income in a taxable year. The United States shareholder must include his pro rata share (determined under the rules of 1.951-1(e)) of each recharacterized amount in income as subpart F income in such separate category for the taxable year.


26 CFR § 1.952-1

Scoping language

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