The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1968 - 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 7
... controlled foreign corporation's qualified investments in less developed countries . 1.955-3 Election as to date of determining qualified investments in less ... Foreign corporations with variation in foreign tax 7 Title 26 Chapter I.
... controlled foreign corporation's qualified investments in less developed countries . 1.955-3 Election as to date of determining qualified investments in less ... Foreign corporations with variation in foreign tax 7 Title 26 Chapter I.
Page 152
... corporation is a controlled foreign corporation bears to the entire year , reduced by ( B ) The amount of distributions received by any other person during such year as a dividend with respect to such stock , but only to the extent of ...
... corporation is a controlled foreign corporation bears to the entire year , reduced by ( B ) The amount of distributions received by any other person during such year as a dividend with respect to such stock , but only to the extent of ...
Page 153
... corporation's increase in earnings invested in United States prop- erty for such taxable year of the corpo- ration ... controlled foreign corporation . See paragraph ( a ) of § 1.957-2 for special limitation on the amount of subpart F ...
... corporation's increase in earnings invested in United States prop- erty for such taxable year of the corpo- ration ... controlled foreign corporation . See paragraph ( a ) of § 1.957-2 for special limitation on the amount of subpart F ...
Page 155
... corporation is a controlled foreign cor- poration bears to the entire taxable year . The amount determined under the preceding sentence , however , shall be taken into account under paragraph ( a ) ( 3 ) of this section only to the ...
... corporation is a controlled foreign cor- poration bears to the entire taxable year . The amount determined under the preceding sentence , however , shall be taken into account under paragraph ( a ) ( 3 ) of this section only to the ...
Page 156
... Corporation A has accumulated earnings and profits for 1963 of $ 700 ; therefore , for purposes of this paragraph ... controlled foreign corporation ) shall be determined by excluding the day on which such asset is acquired and in ...
... Corporation A has accumulated earnings and profits for 1963 of $ 700 ; therefore , for purposes of this paragraph ... controlled foreign corporation ) shall be determined by excluding the day on which such asset is acquired and in ...
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Common terms and phrases
adjusted basis allocated allowed 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 387 - If the property was acquired by gift after December 31, 1920, the basis shall be the same as it would be in the hands of the donor or the last preceding owner by whom it was not acquired by gift...
Page 143 - 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 three-year 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 367 - 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 90 - States, the amount of any such taxes paid or accrued during the taxable year to any foreign country, if the foreign country of which such alien resident is a citizen or subject, in imposing such taxes, allows a similar credit to citizens of the United States residing in such country; and (4) PARTNERSHIPS AND ESTATES.
Page 137 - Indies, and which satisfies the following conditions : (1) if 95 percent or more of the gross income of such domestic corporation for the 3-year period immediately preceding the close of the taxable year (or for such part of such period during which the corporation was in existence...
Page 63 - ... engaged in trade or business within the United 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...
Page 89 - ... (1) Citizens and domestic corporations. In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profIts taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) Resident of the United States or Puerto Rico.
Page 122 - Secretary or his delegate that he has been a bona flde resident of a foreign country or countries for an uninterrupted period which includes an entire taxable year, amounts received from sources without the United States...
Page 52 - 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 can not definitely be allocated to some item or class of gross income.
Page 52 - States as provided in subsection (a) (2) of this section; (3) Compensation for labor or personal services performed without the United States; (4) Rentals or royalties from property located without the United States or from any interest in such property including rentals or royalties for the use of or for the privilege of using without the United States...