The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1992 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
adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation December 31 deduction deemed paid dends determined distribution domestic corporation dual capacity taxpayers earnings and profits effectively connected earnings eign corporation election entity estate investment trust Example fair market value foreign country Foreign income taxes foreign loss account foreign mineral income foreign source foreign tax credit graph gross income income from sources interest expense levy liability limitation income ment nonresident alien individual overall foreign loss partnership passive income payment poration post-October pursuant qualified real estate investment real property holding real property interest received related person resident residual grouping respect shareholder source income statutory grouping subdivision subparagraph tax treaty taxable years beginning taxes paid terest tion trade or business treated U.S. assets U.S. real property U.S. tax U.S. trade unit investment trust unused foreign tax X tax
Popular passages
Page 98 - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income.
Page 449 - 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 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 300 - 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 235 - Gains, profits and income from (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within...
Page 54 - 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 84 - ... is greater than the excess of the net long-term capital gain over the net short-term capital loss of the taxable year, the portion of each distribution which shall be a capital gain dividend shall be only that proportion of the amount so designated which such excess of the net long-term capital gain over the net short-term capital loss bears to the aggregate amount so designated.
Page 112 - ... amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.
Page 62 - If the determination of such amount depends in whole or in part on the income or profits derived by any person from such property (except that any amount so received or accrued shall not be excluded from the term "rents from real property...
Page 278 - ... extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily in the United States, he becomes a resident, though it may be his intention at all times to return to his domicile abroad when the purpose for which he came has been consummated or abandoned. An alien whose stay in the United States is limited to a definite period by the immigration laws is not a resident of the United States within the meaning of this section. In the absence of exceptional...
Page 111 - States if — (A) The labor or services are performed by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year...