{"data":{"id":"us/26-cfr-1.956-1t","jurisdiction":"us","citation":"26 CFR 1.956-1T","heading":"-1T Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).","body":"(a)-(e)(4) [Reserved]\n(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.\n(e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).\n(f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.\n(g)-(h) [Reserved]","path":["Title 26—Internal Revenue","CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY","SUBCHAPTER A—INCOME TAX","PART 1—INCOME TAXES"],"source_url":"https://www.ecfr.gov/api/versioner/v1/full/2026-08-25/title-26.xml","current_through":"2026-08-25","vintage":"","retrieved_at":"2026-08-27T02:25:11Z","sha256":"313cd87626d3bbd1e925c0ccf5ccce0fdf539abd02a6d6087a3872481e4aa8c6","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-1.956-1","next":"us/26-cfr-1.956-2"},"notice":"GroundRules: Original legal text. Not legal advice."}