Exception for certain interest, dividends, rents, and royalties received from a related person
Exception for certain interest, dividends, rents, and royalties received from a related person For purposes of section 1297(b)(2)(C), interest, dividends, rents, or royalties actually received or accrued by a tested foreign corporation are considered received or accrued from a related person only if the payor of the interest, dividend, rent, or royalty is a related person (within the meaning of section 954(d)(3)) with respect to the tested foreign corporation, taking into accountparagraph (c)(1)(i)(D)of this section. For rules determining when amounts received or accrued by a look-through subsidiary or look-through partnership (and treated as received directly by a tested foreign corporation pursuant to section 1297(c) and 1.12972(b)(2) and (b)(3)) are treated as received from a related person, see 1.12972(d).