| United States. Internal Revenue Service - 1936 - 604 pages
...such controlled foreign corporation to any foreign country or to any pos!*ssion of the United States, upon or with respect to the accumulated Profits of...foreign corporation from which such dividends were 307 paid, which the amount of any such dividends received bears to the amount of such accumulated profits.... | |
| 1924 - 1040 pages
...corporation to any foreign country or to any possession of the United States, upon or with resnect sition that morality can be maintained withmit religion. Whatever may be conceded to credit allowed to any domestic corporation under this subdivision shall in no cape exceed the fíame... | |
| United States. Board of Tax Appeals - 1939 - 1380 pages
...to have paid the same proportion of any income * * * taxes paid by such foreign corporation to auy foreign country * * * upon or with respect to the...dividends bears to the amount of such accumulated profits • * *. Note that (f) allows no credit but merely provides that the domestic parent shall be deemed... | |
| 1941 - 1688 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... | |
| 1940 - 1806 pages
...such controlled foreign corporation to any foreign country or to any possession of the United States, 39 any such dividends received bears to the amount of such accumulated profits. The amount of taxes deemed... | |
| 1939 - 1030 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... | |
| United States - 1953 - 1744 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...such dividends were paid, which the amount of such dividend: bears to the amount of such accumulated profits: Provided, That the amount of tax deemed... | |
| United States. Board of Tax Appeals - 1941 - 1630 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...corporation from which such dividends were paid, which the amonnt of inch dividends bears to the amonnt of such accumulated profits : J'roi'iifd, That the amount... | |
| United States - 1964 - 1098 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... | |
| United States. Tax Court - 1944 - 1686 pages
...dividends in any taxable year shall be deemed to have paid the same proportion of any income * * * taxes paid by such foreign corporation to any foreign...bears to the amount of such accumulated profits." The term "accumulated profits" is defined in the subsection as the amount of the foreign corporation's... | |
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