The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1977 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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Common terms and phrases
allocable amount apply apportioned apportionment attributable basis chain or group class of stock controlled foreign corporation Corporation's country or possession December 31 deduction derived from sources determined DISC domestic corporation earnings and profits effectively connected eign corporation election Example excess profits taxes excluded export trade assets filed first-tier corporation foreign base company foreign country foreign income taxes foreign mineral income foreign tax credit graph gross income Guam income derived income from sources income taxes paid interest less developed country ment minimum distribution nonresident alien individual paid or accrued paragraph percent period poration Puerto Rico ration real estate investment respect section 901 shareholder's spect statutory grouping Statutory provisions subdivision subparagraph subpart F income subsection taxable income taxable year beginning taxes deemed paid taxpayer tion trade or business treated trolled foreign corporation U.S. tax unit investment trust United States dollars United States shareholder unused foreign tax
Popular passages
Page 122 - 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 202 - 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 417 - 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 298 - ... is allowed whether or not connected with income from sources within the United States. The proper apportionment and allocation of the deductions with respect to sources within and without the United States shall be determined as provided in part I (section 861 and following), subchapter N, chapter 1 of the Code, and the regulations thereunder.
Page 311 - Treasury or his delegate — (1) the amount which, during the year ending on the date fixed by law for filing the return, the corporation has distributed as a special dividend...
Page 293 - ... 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 without the United States; and (2) If 90 percent or more of its gross income for such period or such part thereof was derived from the active conduct of a trade or business.
Page 215 - States, the amount of any such taxes paid or accrued during the taxable year to any possession of the United States; and (3) ALIEN RESIDENT OF UNITED STATES. — In the case of an alien resident of the United States, the amount of any such taxes paid or accrued during the taxable year to...
Page 83 - States, shall be treated as derived entirely from sources within the country in which sold, except that gains, profits, and income derived from the purchase of personal property within a possession of the United States and its sale within the United States shall be treated as derived partly from sources within and partly from sources without the United States. (f) DEFINITIONS. — As used in this- section the words "sale" or "sold" include "exchange" or "exchanged"; and the word "produced" includes...
Page 213 - 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 - ... properly apportioned or allocated thereto and a ratable part of other expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income. The remainder, if any, shall be included in full as net income from sources within the United States.