| Robert Hiester Montgomery - 1923 - 1760 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...amount of such accumulated profits: Provided, That the credit allowed to any domestic corporation under this subdivision shall in no case exceed the same... | |
| 1954 - 766 pages
...to any роажоыол of the United States, upon or with respect to the accumulated profits of the corporation from which such dividends were paid, which...the amount of such dividends bears to the amount of ouch accumulated profits. (g) Corporations Treated as Foreign— For the purpose* of this section the... | |
| Robert Hiester Montgomery - 1927 - 1510 pages
...dividend received from the foreign subsidiary. It has been suggested that the phrase in section 238 (e) "upon or with respect to the accumulated profits of...corporation from which such dividends were paid," might limit the credit for taxes as shown in the above illustration to an amount allocated to the $16,000... | |
| Robert Hiester Montgomery - 1927 - 1510 pages
...dividend received from the foreign subsidiary. It has been suggested that the phrase in section 238 (e) "upon or with respect to the accumulated profits of...foreign corporation from which such dividends were paid,1' might limit the credit for taxes as shown in the above illustration to an amount allocated... | |
| United States. Internal Revenue Service - 1931 - 502 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...amount of such accumulated profits : Provided, That the credit allowed to any domestic corporation under this subsection shall in no case exceed the same proportion... | |
| United States. Internal Revenue Service - 1932 - 192 pages
...such controlled foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. The credit for taxes deemed... | |
| United States. Bureau of Internal Revenue - 1933 - 452 pages
...such controlled foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. The amount of taxes deemed... | |
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