TaxGuided
United States IRC sections

Statute section

IRC section 951

Amounts included in gross income of United States shareholders

Country

United States

Section

951

Updated

2026-05-20

Operative text

Section 951 includes Subpart F income of a controlled foreign corporation in the gross income of its U.S. shareholders. Subpart F income includes specified categories of mobile income such as foreign personal holding company income and foreign base company sales and services income.

Cross-references

26 U.S.C. 95426 U.S.C. 957

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Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.