{"data":{"id":"us/26-cfr-1.959-4","jurisdiction":"us","citation":"26 CFR 1.959-4","heading":"-4 Distributions to United States persons not counting as dividends.","body":"Except as provided in section 960(a)(3) and § 1.960-2, any distribution to a United States person which is excluded from the gross income of such person under section 959(a)(1) and § 1.959-1 shall be treated for purposes of chapter 1 (relating to normal taxes and surtaxes) of subtitle A (relating to income taxes) of the Code as a distribution which is not a dividend. However, see paragraph (b)(1) of § 1.956-1, relating to the dividend limitation on the amount of a controlled foreign corporation's investment of earnings in United States property.","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":"ffb8ef82a50962b0725d3428044f39d6c2ac69b87faa4f8da8efd4c5ac8154cb","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-1.959-3","next":"us/26-cfr-1.960-1"},"notice":"GroundRules: Original legal text. Not legal advice."}