Reg. § 1.954(c)(6)-1 Certain cases in which section 954(c)(6) exception not available.
(a) Cross-references to other rules For a non-exclusive list of rules that in certain cases limit the applicability of the exception to foreign personal holding company income under section , see—
(1) Section (rules regarding the application of section to extraordinary disposition amounts);
(2) Section (rules regarding the application of section to tiered extraordinary reduction amounts);
(3) Section (rules regarding tiered hybrid dividends);
(4) Section (rules regarding income inclusion and gain recognition in certain exchanges following an inversion transaction);
(5) Section (rules regarding certain gain from the sale or exchange of stock that is recharacterized as a dividend); and
(6) Section (rules regarding recharacterization of certain transactions following an inversion transaction).
(b) Applicability date This section applies as of August 27, 2020.
[T.D. 9909, 85 FR 53097, Aug. 27, 2020]