SECTION 4. SECTION 956 GUIDANCE

Future guidance will provide that, for purposes of applying § 1.956–2(b)(1)(vi), an aircraft or vessel used in the transportation of persons or property in foreign commerce is excluded from U.S. property under § 1.956–2(b)(1)(vi) if rents derived from leasing such aircraft or vessel are excluded from foreign personal holding company income under section 954(c)(2)(A) and such property is considered to be used predominately outside the United States under § 1.956–2(b)(1)(vi), determined by substituting the phrase “more than 50 percent” for the phrases “70 percent or more” or “70 percent.” For purposes of determining whether an aircraft or vessel is used in foreign commerce, the definition of “foreign commerce” contained in § 1.954–6(b)(3) shall continue to apply.