Definition of Foreign Base Company Income and Foreign Personal Holding Company Income of a Controlled Foreign Corporation

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This document contains proposed Income Tax Regulations relating to the definitions of subpart F income and foreign personal holding company income of a controlled foreign corporation and the allocation of deficits for purposes of computing the deemed-paid foreign tax credit. These proposed regulations are necessary to provide guidance that coordinates with guidance provided in final regulations under section 954, published elsewhere in this issue of the Federal Register. These regulations will affect United States shareholders of controlled foreign corporations. This document also contains a notice of hearing on these regulations.