Increase in earnings invested in United States property

(i) Increase in earnings invested in United States property. Books or records sufficient to verify the increase for the taxable year in earnings invested by the controlled foreign corporations in United States property must establish (1) The amount of such corporation's earnings invested in United States property (as defined in section 956(b)(1) and paragraph (a) of 1.956-2) at the close of the current and preceding taxable years, as determined under paragraph (b) of 1.956-1, (2) The amount of excluded property described in section 956(b)(2) and paragraph (b) of 1.956-2 held by such corporation at the close of such years, (3) The earnings and profits, to which section 959(c)(1) and paragraph (b)(1) of 1.959-3 apply, distributed by such corporation during the preceding taxable year, and (4) The amount of increase in earnings invested by such corporation in United States property which is excluded from the United States shareholder's gross income for the taxable year under section 959(a)(2) and paragraph (c) of 1.959-1.

Source

26 CFR § 1.964-4


Scoping language

None
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