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The law › Title 26, Internal Revenue Code › Chapter 1

26 U.S.C. 951: Amounts included in gross income of United States shareholders

Created in 1962 by Public Law 87-834. Changed by 11 later laws. 1 new law this Congress changed it.

This Congress

  • H.R. 1 An act to provide for reconciliation pursuant to title II of H. Con. Res. 14. · became law · changed the section as a whole

How it got here

2017

  • Pub. L. 115–97, §14215(a), substituted "at any time" for "for an uninterrupted period of 30 days or more" in introductory provisions. Law text · (a)
  • Pub. L. 115–97, §14212(b)(1)(A), amended subpar. (A) generally. Prior to amendment, subpar. (A) read as follows: "the sum of— Law text · (a)
  • Pub. L. 115–97, §14212(b)(2), struck out par. (3). Text read as follows: "For purposes of paragraph (1)(A)(iii), the pro rata share of any United States shareholder of the previously excluded subpart F income of a controlled foreign corporation withdrawn from investment in foreign b… Law text · (a)
  • Pub. L. 115–97, §14214(a), inserted ", or 10 percent or more of the total value of shares of all classes of stock of such foreign corporation" after "such foreign corporation". Law text · (b)
  • Pub. L. 115–97, §14101(e)(1), substituted "title" for "subpart". Law text · (b)

2007

  • Pub. L. 110–172 redesignated subsec. (d) as (c) and struck out heading and text of former subsec. (c). Text read as follows: (Tax Technical Corrections Act of 2007) Law text · (c), (d)

2004

  • Pub. L. 108–357 redesignated subsecs. (e) and (f) as (c) and (d), respectively, and struck out former subsecs. (c) and (d), which related to coordination of provisions with election of a foreign investment company to distribute income and coordination with foreign personal hold… (American Jobs Creation Act of 2004) Law text · (c), (d), (e), (f)

1997

  • Pub. L. 105–34 inserted concluding provisions "For purposes of subparagraph (B), any gain included in the gross income of any person as a dividend under section 1248 shall be treated as a distribution received by such person with respect to the stock involved." (Taxpayer Relief Act of 1997) Law text · (a)

1996

  • Pub. L. 104–188 inserted "and" at end of subpar. (A), substituted period for "; and" at end of subpar. (B), and struck out subpar. (C) which read as follows: "the amount determined under section 956A with respect to such shareholder for such year (but only to the extent no… (Small Business Job Protection Act of 1996) Law text · (a)

1993

  • Pub. L. 103–66, §13232(c)(1), substituted "the amount determined under section 956 with respect to such shareholder for such year (but only to the extent not excluded from gross income under section 959(a)(2)); and" for "his pro rata share (determined under section 956(a)(2)) of … · (a)
  • Pub. L. 103–66, §13231(a), added subpar. (C). · (a)
  • Pub. L. 103–66, §13232(c)(2), struck out heading and text of par. (4). Text read as follows: "For purposes of paragraph (1)(B), the pro rata share of any United States shareholder in the increase of the earnings of a controlled foreign corporation invested in United States property … · (a)

1988

  • Pub. L. 100–647 substituted "section 957(c)" for "section 957(d)". · (b)

1986

  • Pub. L. 99–514, §1876(c)(2), struck out last sentence which read as follows: "For purposes of the preceding sentence, income described in paragraph (2) or (3) of section 921(d) shall be treated as derived from sources within the United States." · (e)
  • Pub. L. 99–514, §1235(c), added subsec. (f). · (f)

1984

  • Pub. L. 98–369, §132(c)(1), amended subsec. (d) generally, substituting provision that, if a United States shareholder is required to include in gross income an amount under both subsec. (a)(1)(A)(ii) of this section and section 551(b) of this title, such amount be included only under … · (d)
  • Pub. L. 98–369, §801(d)(4), added subsec. (e). · (e)

1976

  • Pub. L. 94–455 struck out "beginning after December 31, 1962" after "during any taxable year". · (a)

1975

  • Pub. L. 94–12, §602(a)(3)(B), struck out "except as provided in section 963," before "his pro rata share". · (a)
  • Pub. L. 94–12, §602(c)(3), substituted "(determined under section 955(a)(3) as in effect before the enactment of the Tax Reduction Act of 1975)" for "(determined under section 955(a)(3))". · (a)
  • Pub. L. 94–12, §602(d)(2)(A), added cl. (iii). · (a)
  • Pub. L. 94–12, §602(c)(4), (d)(2)(B), substituted "paragraph (i)(A)(iii)" for "paragraph (1)(A)(ii)" and "foreign base company shipping operations" for "less developed countries". · (a)

Text, outline and history from the official U.S. Code (2024 edition) on GovInfo, published by the Office of the Law Revision Counsel. Changes made after that edition appear under This Congress.