The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1973 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. |
Other editions - View all
Common terms and phrases
adjusted basis allocated allowed amount apply attributable capital gain chain or group class of stock computed controlled foreign corporation Corporation's December 31 deductions derived from sources determined dividends domestic corporation earnings and profits election erty estate investment trust excluded fair market value first-tier corporation foreign base company foreign country foreign income tax foreign tax credit gain or loss graph gross income income derived income from sources income under section interest less developed country liability ment minimum distribution paid or accrued paragraph percent period poration Puerto Rico purchased qualified investments rata share reacquisition real estate investment real property received related person respect sale or exchange section 951 Statutory provisions stock or securities subdivision subparagraph subpart F income subsection taxable income taxes paid taxpayer tion trade or business treated trolled foreign corporation unit investment trust United States dollars United States shareholder unused foreign tax
Popular passages
Page 482 - ... money, then the gain, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property.
Page 111 - 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 title.
Page 158 - The following Items shall not be Included In gross Income and shall be exempt from taxation under this subtitle: (1) Bona fide resident of foreign country.
Page 125 - ... (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 173 - 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) was derived from sources...
Page 483 - In this paragraph shall be allocated between the properties (other than money) received, and for the purpose of the allocation there shall be assigned to such other property an amount equivalent to Its fair market value at the date of the exchange.
Page 480 - ... held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
Page 64 - Rentals or royalties from property located in the United States or from any interest in such property, including rentals or royalties for the use of or for the privilege of using in the United States, patents, copyrights, secret processes and formulas, good will, trademarks, trade brands, franchises, and other like property; and (5) Gains, profits, and income from the sale of real property located in the United States.
Page 454 - If the property was acquired after December 31, 1920, by a transfer in trust (other than by a transfer in trust by a gift, bequest, or devise) the basis shall be the same as it would be in the hands of the grantor, increased in the amount of gain or decreased in the amount of loss recognized to the grantor upon such transfer under the law applicable to the year in which the transfer was made.
Page 483 - For purposes of this section, section 1035 (a), and section 1036 (a), where as part of the consideration to the taxpayer another party to the exchange assumed a liability of the taxpayer or acquired from the taxpayer property subject to a liability, such assumption or acquisition (in the amount of the liability) shall be considered as money received by the taxpayer on the exchange.