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" ... taxes 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 foreign corporation from which such dividends were paid, which the amount of such dividends... "
Cases Decided in the Court of Claims of the United States - Page 739
by United States. Court of Claims - 1944
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Code of Federal Regulations: Containing a Codification of Documents of ...

1977 - 866 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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The Code of Federal Regulations of the United States of America

1978 - 952 pages
...foreign country or to any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends bears to the amount of such accumulated profite. (b) Foreign subsidiary of first and second foreign corporation. (1) If the foreign corporation...
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Code of Federal Regulations: Containing a Codification of Documents of ...

1966 - 764 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 sucii distribution Is made, which were not deemed paid by the domestic corporation under paragraph...
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Federal Income, Estate and Gift Tax Laws, Correlated: Being a Correlation of ...

United States, Walter Elbert Barton - 1950 - 1126 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...dividends bears to the amount of such accumulated profits. The term "accumulated profits" when used in this subsection in reference to a foreign corporation,...
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Statistics of Income from Returns of Net Income

United States. Internal Revenue Service - 1951 - 1868 pages
...paid by such foreign corporation to any foreign country or to any possession of the Unitea States, upon or with respect to the accumulated profits of...the amount of such dividends bears to the amount of suc h accumulated profits. The term "accumulated profits" when used in this subsection in reference...
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Internal Revenue Bulletin: Cumulative bulletin

United States. Internal Revenue Service - 1963 - 1436 pages
...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...dividends bears to the amount of such accumulated profits. Section 902(c) of the Code prior to its amendment by section 9(a) of the Revenue Act of 1962 reads...
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Federal Income, Estate, and Gift Tax Laws, Correlated: Being a Correlation ...

United States, Walter Elbert Barton - 1953 - 708 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...were paid, which the amount of such dividends bears i to the amount of such accumulated , profits. The term "accumulated profits" when used in this subsection...
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Internal Revenue Bulletin: Cumulative bulletin, Part 3

United States. Internal Revenue Service - 1963 - 1402 pages
...country or top any possession of the United States on or with respect to such accumulated profits, which the amount of such dividends bears to the amount of such accumulated profits. (b) FOREIGN SUBSIDIARY or FOREIGN CORPORATION. — If such foreign corporation owns 50 percent or more...
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Statistics of Income from Returns of Net Income

United States. Internal Revenue Service - 1955 - 752 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. The term "accumulated profits" when used...
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"Gross-up" in Connection with Foreign Tax Credit Allowed Domestic ...

United States. Congress. House. Committee on Ways and Means - 1960 - 92 pages
...Subsections (a) and (b) of section 902 of the Internal Revenue Code of 1954 are each amended by striking out "which the amount of such dividends bears to the amount of such accumulated profits" and inserting in lieu thereof "which the amount of such dividends (determined without regard to subsection...
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