Sec. 1.902-5 Effective dates for the application of section 902 (as amended by Revenue Act of 1962). 1.903 Statutory provisions; credit for taxes in lieu of income, etc., taxes. 1.903-1 Definition of taxes in lieu of income, war profits, or excess profits taxes. 1.904 Statutory provisions; limitation on credit. 1.904-1 Limitation on credit for foreign taxes. 1.904-2 Carryback and carryover of unused foreign tax. 1904-3 Carryback and carryover of unused foreign tax by husband and wife. 1.905 Statutory provisions; applicable rules. 1.905-1 When credit for taxes may be taken. 1.905-2 1.905-3 Conditions of allowance of credit. Redetermination of the tax when credit proves incorrect. 1.905-4 Credit for taxes accrued but not paid. 1.905-5 Credit for United Kingdom income taxes paid with respect to royalties. EARNED INCOME OF CITIZENS OF UNITED STATES 1.911 Statutory provisions; earned income from sources without the United States. 1.911-1 Earned income from sources without the United States attributable to services performed before 1963. 1.911-2 Earned income from sources without the United States attributable to services performed after 1962. 1.912 Statutory provisions; exemption for certain allowances. 1.912-1 Exclusion of certain cost-of-living allowances. 1.912-2 Exclusion of certain allowances of Foreign Service personnel. WESTERN HEMISPHERE TRADE CORPORATIONS 1.921 Statutory provisions; definition of Western Hemisphere trade corporations. 1.921-1 Definition of Western Hemisphere trade corporation. 1.922 Statutory provisions; special deduction. 1.922-1 Special deduction of Western Hemisphere trade corporation. POSSESSIONS OF THE UNITED STATES 1.931 Statutory provisions; income from sources within possessions of the United States. 1.931-1 Citizens of the United States and domestic corporations deriving income from sources within a certain possession of the United States. 1.932 Statutory provisions; taxation of citizens of possessions of the United States. 1.932-1 Status of citizens of United States possessions. 1.933 Statutory provisions; income from sources within Puerto Rico. 1.933-1 Exclusion of certain income from sources within Puerto Rico. 1.934 Statutory provisions; limitation on reduction in income tax liability incurred to the Virgin Islands. 1.934-1 Limitation on reduction in income tax liability incurred to the Virgin Islands. CHINA TRADE ACT CORPORATIONS 1.941 Statutory provisions; special deduction for China Trade Act corporations. 1.941-1 Special deduction for China Trade Act corporations. 1.941-2 Meaning of terms used in connection with China Trade Act corporations. 1.941-3 Illustration of principles. 1.942 Statutory provisions; disallowance of foreign tax credit. 1.943 Statutory provisions; exclusion of dividends to residents of Formosa or Hong Kong. 1.943-1 Withholding by a China Trade Act corporation. CONTROLLED FOREIGN CORPORATIONS 1.951 Statutory provisions; amounts included in gross income of United States shareholders. 1.951-1 Amounts included in gross income of United States shareholders. 1.951-2 Coordination of subpart F with election of a foreign investment company to distribute income. 1.951-3 Coordination of subpart F with foreign personal holding company pro visions. 1.952 Statutory provisions; subpart F income defined. 1.952-1 Subpart F income defined. Sec. 1.952-2 Determination of gross income and taxable income of a foreign corporation. 1.953 Statutory provisions; income from insurance of United States risks. 1.953-1 1.953-2 Income from insurance of United States risks. 1.953-3 Risks deemed to be United States risks. 1.953-4 Taxable income to which section 953 applies. 1.953-5 Corporations not qualifying as insurance companies. 1.953-6 Relationship of sections 953 and 954. 1.954 Statutory provisions; foreign base company income. 1.954-1 1.954-2 1.954-3 Foreign base company income. Foreign personal holding company income. 1.954 4 Foreign base company services income. 1.954-5 Increase in qualified investments in less developed countries. 1.955 Statutory provisions; withdrawal of previously excluded subpart F income from qualified investment. 1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries. 1.955-2 Amount of a controlled foreign corporation's qualified investments in less developed countries. 1.955-3 Election as to date of determining qualified investments in less developed countries. 1.955-4 Definition of less developed country. 1.955-5 Definition of less developed country corporation. 1.955-6 Gross income from sources within less developed countries. 1.956 Statutory provisions; investment of earnings in United States property. 1.956-1 Shareholders pro rata share of a controlled foreign corporation's increase in earnings invested in United States property. 1.956-2 Definition of United States property. 1.957 Statutory provisions; controlled foreign corporations; United States persons. 1.957-1 Definition of controlled foreign corporation. 1.957-2 Controlled foreign corporation deriving income from insurance of United States risks. 1.957-3 Corporations organized in United States possessions. 1.957-4 United States person defined. 1.958 Statutory provisions; rules for determining stock ownership. 1.958-1 Direct and indirect ownership of stock. 1.958-2 Constructive ownership of stock. 1.959 Statutory provisions; exclusion from gross income of previously taxed earnings and profits. 1.959-1 Exclusion from gross income of United States persons of previously taxed earnings and profits. 1.959-2 Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits. 1.959-3 Allocation of distributions to earnings and profits of foreign corporations. 1.959-4 Distributions to United States persons not counting as dividends. 1.961 Statutory provisions; adjustments to basis of stock in controlled foreign corporations and of other property. 1.961-1 Increase in basis of stock in controlled foreign corporations and of other property. 1.961-2 Reduction in basis of stock in foreign corporations and of other property. 1.962 Statutory provisions; election by individuals to be subject to tax at corporate rates. 1.962-1 Limitation of tax for individuals on amounts included in gross income under section 951(a). 1.962-2 Election of limitation of tax for individuals. 1.963 Statutory provisions; receipt of minimum distributions by domestic corporations. 1.963-1 Exclusion of subpart F income upon receipt of minimum distribution. 1.963-2 Determination of the amount of the minimum distribution. 1.963-3 Distributions counting toward a minimum distribution. 1.963-4 Limitations on minimum distribution from a chain or group. Sec. 1.963-5 Foreign corporations with variation in foreign tax rate because of distributions. 1.963-6 Deficiency distribution. 1.963-7 Transitional rules for certain taxable years. 1.964 Statutory provisions; miscellaneous provisions. 1.964-1 1.964-2 Determination of the earnings and profits of a foreign corporation. 1.964-3 Records to be provided by United States shareholders. 1.964-4 Verification of certain classes of income. EXPORT TRADE CORPORATIONS 1.970 Statutory provisions; reduction of subpart F income of export trade corporations. 1.970-1 Export trade corporations. 1.970-2 Elections as to date of determining investments in export trade assets. 1.970-3 Effective date of subpart G. 1.971 Statutory provisions; definitions. 1.971-1 Definitions with respect to export trade corporations. 1.972 Statutory provisions; consolidation of group of export trade corporations. 1.972-1 Consolidation of group of export trade corporations. 1.1001 GAIN OR LOSS ON DISPOSITION OF PROPERTY DETERMINATION OF AMOUNT OF AND RECOGNITION OF GAIN OR LOSS Statutory provisions; determination of amount of and recognition of gain or loss. 1.1001-1 Computation of gain or loss. 1.1002 Statutory provisions; recognition of gain or loss. 1.1002-1 Sales or exchanges. BASIS RULES OF GENERAL APPLICATION 1.1011 Statutory provisions; adjusted basis for determining gain or loss. 1.1011-1 Adjusted basis. 1.1012 Statutory provisions; basis of property-cost. 1.1012-1 Basis of property. 1.1012-2 Transfers in part a sale and in part a gift. 1.1013 Statutory provisions; basis of property included in inventory. 1.1013-1 Property included in inventory. 1.1014 Statutory provisions; basis of property acquired from a decedent. 1.1014-1 Basis of property acquired from a decedent. 1.1014-2 Property acquired from a decedent. 1.1014-3 Other basis rules. 1.1014-4 Uniformity of basis; adjustment to basis. 1.1014-5 Gain or loss. 1.1014-6 Special rule for adjustments to basis where property is acquired from a decedent prior to his death. 1.1014-7 Example applying rules of §§ 1.1014-4 through 1.1014-6 to case involving multiple interests. 1.1014-8 Bequest, devise, or inheritance of a remainder interest. 1.1015 Statutory provisions; basis of property acquired by gifts and transfers in trust. 1.1015-1 Basis of property acquired by gift after December 31, 1920. 1.1015-2 Transfer of property in trust after December 31, 1920. 1.1015-3 Gift or transfer in trust before January 1, 1921. 1.1015-4 Transfers in part a gift and in part a sale. 1.1015-5 Increased basis for gift tax paid. 1.1016 Statutory provisions; adjustments to basis. 1.1016-1 Adjustments to basis; scope of section. 1.1016-2 Items properly chargeable to capital account. 1.1016-3 Exhaustion, wear and tear, obsolescence, amortization, and depletion for periods since February 28, 1913. 1.1016-4 Exhaustion, wear and tear, obsolescence, amortization, and depletion; periods during which income was not subject to tax. 1.1016-5 Miscellaneous adjustments to basis. 1.1016-6 Other applicable rules. 1.1016-7 Adjusted basis; cancellation of indebtedness under Bankruptcy Act. Sec. 1.1016-8 Adjusted basis; cancellation of indebtedness; special cases. 1.1016-9 Adjusted basis; mutual savings banks, building and loan associations, and cooperative banks. 1.1016-10 Substituted basis. 1.1017 Statutory provisions; discharge of indebtedness. 1.1017-1 Adjusted basis; discharge of indebtedness; general rule. 1.1017-2 Adjusted basis; discharge of indebtedness; special cases. 1.1018 Statutory provisions; adjustment of capital structure before September 22, 1938. 1.1018-1 Adjusted basis; exception to section 270 of the Bankruptcy Act, as amended. 1.1019 Statutory provisions; property on which lessee has made improvements. 1.1019-1 Property on which lessee has made improvements. 1.1020 Statutory provisions; election in respect of depreciation, etc., allowed before 1952. 1.1020-1 Election as to amounts allowed in respect of depreciation, etc., before 1952. 1.1021 Statutory provisions; sale of annuities. 1.1021-1 Sale of annuities. 1.1022 Statutory provisions; cross references. COMMON NONTAXABLE EXCHANGES 1.1031(a) Statutory provisions; exchange of property held for productive use or investment; nonrecognition of gain or loss from exchanges solely in kind. 1.1031(a)-1 Property held for productive use in trade or business or for investment. 1.1031(b) Statutory provisions; exchange of property held for productive use or investment; gain from exchanges not solely in kind. 1.1031(b)-1 Receipt of other property or money in tax-free exchange. 1.1031(c) Statutory provisions; exchange of property held for productive use or investment; loss from exchanges not solely in kind. 1.1031(c)-1 Nonrecognition of loss. 1.1031(d) Statutory provisions; exchange of property held for productive use or investment; basis. 1.1031(d)-1 Property acquired upon a tax-free exchange. 1.1031(d)-2 Treatment of assumption of liabilities. 1.1032 Statutory provisions; exchange of stock for property. 1.1032-1 Disposition by a corporation of its own capital stock. 1.1033(a) Statutory provisions; involuntary conversions; general rule. 1.1033(a)-1 Involuntary conversions; nonrecognition of gain. 1.1033(a)-2 Involuntary conversion where disposition of the converted property occurred after December 31, 1950. 1.1033 (a)-3 Involuntary conversion where disposition of the converted property occurred before January 1, 1951. 1.1033(a)-4 Replacement funds where disposition of the converted property occurred before January 1, 1951. 1.1033 (b) Statutory provisions; involuntary conversions; residence of taxpayer. 1.1033 (b)-1 Involuntary conversion of principal residence. 1.1033 (c) Statutory provisions; involuntary conversions; basis of property acquired through involuntary conversion. 1.1033 (c)-1 Basis of property acquired as a result of an involuntary conversion. 1.1033(d) Statutory provisions; involuntary conversions; property sold pursuant to reclamation laws. 1.1033 (d)-1 Disposition of excess property within irrigation project deemed to be involuntary conversion. 1.1033 (e) disease. Statutory provisions; involuntary conversions; livestock destroyed by 1.1033 (e)-1 Destruction or disposition of livestock because of disease. 1.1033 (f) Statutory provisions; livestock sold on account of drought. 1.1033 (f)-1 Sale or exchange of livestock solely on account of drought. 1.1033(g) Statutory provisions; involuntary conversions; condemnation of real property held for productive use in trade or business or for investment. 1.1033 (g)-1 Condemnation of real property held for productive use in trade or business or for investment. 1.1033 (h) 1.1033 (h)-1 Statutory provisions; involuntary conversions; cross references. 1.1034 Statutory provisions; sale or exchange of residence. Sec. 1.1034-1 Sale or exchange of residence. 1.1035 Statutory provisions; certain exchanges of insurance policies. 1.1035-1 Certain exchanges of insurance policies. 1.1036 Statutory provisions; stock for stock of same corporation. 1.1036-1 Stock for stock of the same corporation. 1.1037 Statutory provisions; certain exchanges of United States obligations. 1.1037-1 Certain exchanges of United States obligations. 1.1038 Statutory provisions; certain reacquisitions of real property. 1.1038-1 Reacquisitions of real property in satisfaction of indebtedness. 1.1038-2 Reacquisition and resale of property used as a principal residence. 1.1038-3 Election to have section 1038 apply for taxable years beginning after December 31, 1957. SPECIAL RULES 1.1051 Statutory provisions; property acquired during affiliation. 1.1051-1 Basis of property acquired during affiliation. 1.1052 Statutory provisions; basis established by the Revenue Act of 1932 or 1934 or by the Internal Revenue Code of 1939. 1.1052-1 Basis of property established by Revenue Act of 1932. 1.1052-2 Basis of property established by Revenue Act of 1934. 1.1052-3 Basis of property established by the Internal Revenue Code of 1939. 1.1053 Statutory provisions; basis of property acquired before March 1, 1913. 1.1053-1 Property acquired before March 1, 1913. 1.1054 Statutory provisions; certain stock of Federal National Mortgage Association. 1.1054-1 Certain stock of Federal National Mortgage Association. 1.1055 Statutory provisions; redeemable ground rents. 1.1055-1 General rule with respect to redeemable ground rents. 1.1055-2 Determination of amount realized on the transfer of the right to hold real property subject to liabilities under a redeemable ground rent. 1.1055-3 Basis of real property held subject to liabilities under a redeemable ground rent. 1.1055-4 Basis of redeemable ground rent reserved or created in connection with transfers of real property before April 11, 1963. 1.1056 Statutory provisions; cross references. CHANGES TO EFFECTUATE F.C.C. POLICY 1.1071 Statutory provisions; gain from sale or exchange to effectuate policies of Federal Communications Commission. 1.1071-1 Gain from sale or exchange to effectuate policies of Federal Communications Commission. 1.1071-2 Nature and effect of election. 1.1071-3 Reduction of basis of property pursuant to election under section 1071. 1.1071-4 Manner of election. EXCHANGES IN OBEDIENCE TO S.E.C. ORDERS 1.1081 Statutory provisions; exchanges and distributions in obedience to orders of the Securities and Exchange Commission; nonrecognition of gain or loss. 1.1081-1 Terms used. 1.1081-2 Purpose and scope of exception. 1.1081-3 Exchanges of stock or securities solely for stock or securities. 1.1081-4 Exchanges of property for property by corporations. 1.1081-5 Distribution solely of stock or securities. 1.1081-6 Transfers within system group. 1.1081-7 Sale of stock or securities received upon exchange by members of system group. 1.1081-8 Exchanges in which money or other nonexempt property is received. 1.1081-9 Requirements with respect to order of Securities and Exchange Commission. 1.1081-10 Nonapplication of other provisions of the Internal Revenue Code of 1954. 1.1081-11 Records to be kept and information to be filed with returns. 1.1082 Statutory provisions; basis of property acquired in exchanges and distributions made in obedience to orders of the Securities and Exchange Commission. 1.1082-1 Basis for determining gain or loss. 1.1082-2 Basis of property acquired upon exchanges under section 1081 (a) or (e). |