(a)-(e)(4) [Reserved]
(5) Exclusion for certain recourse obligations. For purposes of § 1.956-1(e)(1) of the regulations, in the case of an investment in United States property consisting of an obligation of a related person, as defined in section 954(d)(3) and paragraph (f) of § 1.954-1, a liability will not be recognized as a specific charge if the liability representing the charge is with recourse with respect to the general credit or other assets of the investing controlled foreign corporation.
(e)(6) [Reserved] For further guidance, see § 1.956-1(e)(6).
(f) Effective/applicability date. Paragraph (e)(5) of this section applies to investments made on or after June 14, 1988.
(g)-(h) [Reserved]
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