Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1999 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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Common terms and phrases
activities adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation debt December 31 deduction dends described in paragraph deter determined distribution domestic corporation earnings and profits effectively connected election entity erty estate investment trust Example exchange fair market value filed foreign cor foreign source foreign tax graph gross income holder income from sources income tax treaty indebtedness inter interest expense liabilities ment method mortgage nonresident alien individual paid paragraph a)(1 partnership payment percent period poration post-October pursuant qualified real estate investment real property holding real property interest received related person REMIC resident respect securities share source income spect statutory grouping subparagraph taxable income taxable years beginning taxpayer terest tion trade or business transaction transfer treated U.S. assets U.S. dollars U.S. real property U.S. shareholder U.S. source unit investment trust United X tax
Popular passages
Page 478 - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.
Page 248 - computer program" is a set of statements or instructions to be used directly or indirectly in a computer in order to bring about a certain result.
Page 500 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
Page 249 - ... 1 ) to reproduce the copyrighted work in copies or phonorecords; (2) to prepare derivative works based upon the copyrighted work; (3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending...
Page 356 - In the case of a nonresident alien individual the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States...
Page 273 - This subparagraph relates to gross income derived from the sale of personal property produced (in whole or in part) by the taxpayer within the United States and sold within a possession of the United States, or produced (in whole or in part) by the taxpayer within a possession of the United States and sold within the United States.
Page 50 - Government securities, securities of other investment companies, and other securities for the purposes of this calculation limited in respect of any one issuer to an amount not greater in value than 5...
Page 548 - 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 (li) the taxes deemed to have been paid or accrued under section 902, 905(b), or 960.
Page 362 - For purposes of this section, the term "earned income" means wages, salaries, or professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered. In the case...
Page 283 - ... a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers ; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom.