SECTION 1. OVERVIEW

Section 956(c) of the Internal Revenue Code defines United States property generally to include tangible property

October 16, 2017 324 Bulletin No. 2017–42

located in the United States. In response to the damage caused by Hurricane Irma and Hurricane Maria, including in the Commonwealth of Puerto Rico and the U.S. Virgin Islands, certain controlled foreign corporations (within the meaning of section 957(a)) (“CFCs”) may need to transport property described in section 1221(a)(1) (“section 1221(a)(1) property”) located in affected areas to the United States (as defined in section 7701(a)(9)) for safekeeping. This notice provides relief for certain such section 1221(a)(1) property that would otherwise constitute United States property.