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" States, on or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends bears to the amount of such accumulated profits. "
Cases Decided in the Court of Claims of the United States - Page 702
by United States. Court of Claims - 1942
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Statistics of Income from Returns of Net Income

United States. Internal Revenue Service - 1955 - 752 pages
...have paid the same proportion of any income, war-profits, or excess-profits taxes paid by such other foreign corporation to any foreign country or to any...United States, upon or with respect to the accumulated profit: of the corporation from which such dividends were paid, which the amount of such dividends...
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Internal Revenue Code of 1954, as Amended and in Force on January 3, 1961

United States, United States. Congress. Joint Committee on Internal Revenue Taxation - 1961 - 1208 pages
...have paid the same proportion of any income, war profits, or excess profits taxes paid or deemed to be to any part of the gross estate the United States, on or witn respect to the accumulated profits of such foreign corporation from which...
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Revenue Act of 1962: Hearings Before the Committee on Finance, United States ...

United States. Congress. Senate. Committee on Finance - 1962 - 754 pages
...profits, or excess profits taxes paid to any foreign country or to any possession of the United States, on or with respect to the accumulated profits of such foreign corporation from which such distribution is made, which were not deemed paid by the domestic corporation under paragraph (1) for...
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Hearings, Reports and Prints of the Senate Committee on Finance, Parts 1-4

United States. Congress. Senate. Committee on Finance - 1962 - 1730 pages
...gross income under section 956, the income, •war profits, and excess profits taxes paid or deemed paid by such foreign corporation to any foreign country or to any possession of the United States in connection with the earnings and profits of such foreign corporations from which...
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Legislative History of the Internal Revenue Code of 1954 ..., Volumes 8-11

Floyd Morse Hubbard, United States. Congress. Joint Committee on Internal Revenue Taxation - 1967 - 1392 pages
...without regard to this subsection." SEC. 902 (revised 1962)— Continued taxes paid or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends...
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Legislative History of H.R. 10650, 87th Congress: The Revenue Act of 1962 ...

United States. Congress. House. Committee on Ways and Means - 1967 - 1468 pages
...have paid the same proportion of any income, war profits, or excess profits taxes paid or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends...
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Internal Revenue Cumulative Bulletin, Issue 1

United States. Internal Revenue Service - 1981 - 808 pages
...income tax paid or deemed to have been paid by such foreign corporation to any foreign country, on or with respect to the accumulated profits of such...dividends were paid, which the amount of such dividends (determined without regard to section 78) bears to the amount of such accumulated profits in excess...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1979 - 664 pages
...or excess profits taxes paid or deemed paid by such foreign corporation to any foreign country, on or with respect to the accumulated profits of such...dividends were paid, which the amount of such dividends (determined without regard to section 78) bears to the amount of such accumulated profits in excess...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1971 - 816 pages
...have paid the same proportion of any income, war profits, or excess profits taxes paid or deemed to be paid by such foreign corporation to any foreign country or to any possession of the United States, on or with respect to such accumulated profits, which the amount of such dividends...
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Internal Revenue Cumulative Bulletin, Part 2

United States. Internal Revenue Service - 1976 - 720 pages
...shall be deemed to have paid a certain portion of any creditable income tax paid or deemed to have been paid by such foreign corporation to any foreign country or to any possession of the United States on or with respect to such accumulated profits. The effect of an allocation under...
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