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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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The Code of Federal Regulations of the United States of America

1949 - 774 pages
...same proportion of any income, warprofits, and excess-profits taxes paid or accrued by such controlled foreign corporation to any foreign country or to any...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. See, however, the limitations...
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The Code of Federal Regulations of the United States of America

1972 - 580 pages
...from gross income under section 959, 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 corporation from which...
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Public Law 94-455.94th Congress: Tax Reform Act of 1976

United States - 1976 - 424 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 the accumulated profits of such foreign corporation from which...
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The Code of Federal Regulations of the United States of America

1967 - 528 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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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 458

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1985 - 1086 pages
.... . . taxes paid or deemed to be paid by such foreign corporation to any foreign country ... on ... the accumulated profits of such foreign corporation...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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Reports of the Tax Court of the United States, Volume 96

United States. Tax Court - 1991 - 968 pages
...section 902(a) and (c)(l), which we have italicized, see supra pp. 415-416, relates the taxes paid to "the accumulated profits of such foreign corporation from which such dividends were paid" (sec. 902(a)) and specifies that "accumulated profits" should be determined without reduction by the...
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The Code of Federal Regulations of the United States of America

1973 - 618 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 at such dividends...
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The Code of Federal Regulations of the United States of America

1969 - 556 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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The Code of Federal Regulations of the United States of America

1968 - 544 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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The Code of Federal Regulations of the United States of America

1966 - 516 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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