The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1971 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Page 107
... shareholder shall be deemed to be paid by such shareholder only for purposes of the foreign tax credit al- lowed under section 901. See § 1.904-1 for other limitations on the amount of the credit . Further , see the regulations under ...
... shareholder shall be deemed to be paid by such shareholder only for purposes of the foreign tax credit al- lowed under section 901. See § 1.904-1 for other limitations on the amount of the credit . Further , see the regulations under ...
Page 109
... United States shareholder to exclude from its gross income for the taxable year the subpart F income of a controlled foreign corporation , the earnings and profits of such foreign corporation for such year with respect to such share ...
... United States shareholder to exclude from its gross income for the taxable year the subpart F income of a controlled foreign corporation , the earnings and profits of such foreign corporation for such year with respect to such share ...
Page 158
... United States shareholder ( as defined in subsection ( b ) ) of such corpora- tion and who owns ( within the meaning of section 958 ( a ) ) stock in such corporation on the last day , in such year , on which such corporation is a ...
... United States shareholder ( as defined in subsection ( b ) ) of such corpora- tion and who owns ( within the meaning of section 958 ( a ) ) stock in such corporation on the last day , in such year , on which such corporation is a ...
Page 159
... in the case of any United States shareholder is the amount- ( A ) Which would have been distributed with respect to the stock which such share- holder owns ( within the meaning of section 958 ( a ) ) in such corporation if on the last ...
... in the case of any United States shareholder is the amount- ( A ) Which would have been distributed with respect to the stock which such share- holder owns ( within the meaning of section 958 ( a ) ) in such corporation if on the last ...
Page 160
... of the corpo- ration , and ( iii ) Such shareholder's pro rata share ( determined under paragraph ( d ) of this section ) of the corporation's increase in earnings invested in United States prop- erty for such taxable year of the corpo ...
... of the corpo- ration , and ( iii ) Such shareholder's pro rata share ( determined under paragraph ( d ) of this section ) of the corporation's increase in earnings invested in United States prop- erty for such taxable year of the corpo ...
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Common terms and phrases
adjusted basis allocated amount apply capital gain chain or group class of stock computed controlled foreign corporation Corporation's December 31 deductions deemed paid derived from sources described in section determined dividends domestic corporation earnings and profits election erty estate investment trust export trade assets fair market value foreign base company foreign country foreign income tax foreign tax credit gain or loss graph gross income holding company income derived income from sources investments in less less developed country liability ment minimum distribution nonresident alien paid or accrued paragraph percent period poration Puerto Rico purchased qualified investments rata share reacquisition real estate investment real property received respect sale or exchange section 959 Statutory provisions stock or securities subdivision subparagraph subpart F income subsection taxable income taxes paid taxpayer tion trade or business trolled foreign corporation United States dollars United States shareholder unused foreign tax
Popular passages
Page 54 - For gains, profits, and income from the sale of personal property, see subsection (e). "(b) NET INCOME FROM SOURCES IN UNITED STATES. — From the items of gross income specified in subsection (a) of this section there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income.
Page 377 - Amount realized. — The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Page 59 - States, the net income may first be computed by deducting the expenses, losses or other deductions apportioned or allocated thereto and a ratable part of any expenses, losses or other deductions which cannot definitely be allocated to some items or class of gross income...
Page 83 - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States shall not be included in gross income and shall be exempt from taxation under this chapter.
Page 147 - States — (1) If 80 per centum or more of the gross income of such citizen or domestic corporation (computed without the benefit of this section), for the threeyear period immediately preceding the close of the taxable year (or for such part of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States...
Page 233 - February 28, 1913, or (2) out of the earnings or profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
Page 54 - ... (B) From a foreign corporation unless less than 50 percent of the gross income of such foreign corporation for the 3 -year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States as determined under the provisions of...
Page 149 - Corporations entitled to the benefits of section 931 are allowed the same deductions from their gross income arising from sources within the United States as are allowed to domestic corporations to the extent that such deductions are connected with such gross income, except that the so-called charitable contribution...
Page 72 - States and not having an office or place of business therein, from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income, a tax...
Page 377 - Supplement B — Computation of Net Income [Supplementary to Subchapter B, Part II] SEC. 111. DETERMINATION OF AMOUNT OF, AND RECOGNITION OF, GAIN OR LOSS. (a) COMPUTATION OF GAIN OR Loss. — The gain from the sale or other disposition of property...