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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 ...

1974 - 666 pages
...possession of the United States by such foreign corporation, on or with respect to the accumulated pronts of such foreign corporation from which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. If dividends are received...
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Public Law 94-455.94th Congress: Tax Reform Act of 1976

United States - 1976 - 424 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 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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The Code of Federal Regulations of the United States of America

1949 - 774 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. See, however, the limitations...
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The Code of Federal Regulations of the United States of America

1967 - 528 pages
...6038(b)) to any foreign country or to any possession of the United States by such foreign corporation, on or with respect to the accumulated profits of such...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. If dividends are received...
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The Code of Federal Regulations of the United States of America

1972 - 580 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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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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Reports of the Tax Court of the United States, Volume 2

United States. Tax Court - 1944 - 1254 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...accumulated profits : Provided, That the amount of taa> deemed to have been paid under this subsection shall in no case exceed the same proportion of...
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Codification of Internal Revenue Laws Submitted to ... by Its Staff ...

United States. Congress. Internal Revenue Taxation Joint Committee - 1933 - 262 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 : Proriiled, That the amount of tux deemed to have been paid under this subsection shall in no case...
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Internal Revenue Bulletin

United States. Internal Revenue Service - 1963 - 1084 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, on 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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