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PART 1-INCOME TAXES

Normal Taxes and Surtaxes

(Continued)

REGULATED INVESTMENT COMPA

NIES AND REAL ESTATE INVESTMENT TRUSTS

Sec. 1.851-1 Definition of regulated investment

company. 1.851-2 Limitations. 1.851-3 Rules applicable to section 851(b)(4). 1.851-4 Determination of status. 1.851-5 Examples. 1.851-6 Investment companies furnishing

capital to development corporations. 1.851-7 Certain unit investment trusts. 1.852–1 Taxation of regulated investment

companies. 1.852-2 Method of taxation of regulated in

vestment companies. 1.852-3 Investment company taxable in

come. 1.852–4 Method of taxation of shareholders

of regulated investment companies. 1.852–5 Earnings and profits of a regulated

investment company. 1.852-6 Records to be kept for purpose of de

termining whether a corporation claiming to be a regulated investment com

pany is a personal holding company. 1.852-7 Additional information required in

returns of shareholders. 1.852-8 Information returns. 1.852-9 Special procedural requirements ap

plicable to designation under section

852(b)(3)(D). 1.852-10 Distributions in redemption of in

terests in unit investment trusts. 1.852-11 Treatment of certain losses attrib

utable to periods after October 31 of a

taxable year. 1.852–12 Non-RIC earnings and profits. 1.853-1 Foreign tax credit allowed to share

holders. 1.853-2 Effect of election. 1.853–3 Notice to shareholders. 1.853-4 Manner of making election. 1.854-1 Limitations applicable to dividends

received from regulated investment com

pany. 1.854-2 Notice to shareholders. 1.854 3 Definitions. 1.855–1 Dividends paid by regulated invest

ment company after close of taxable year.

REAL ESTATE INVESTMENT TRUSTS 1.856-0 Revenue Act of 1978 amendments not TAX BASED ON INCOME FROM SOURCES WITHIN OR WITHOUT THE UNITED STATES

1.856-1 Definition of real estate investment

trust. 1.856-2 Limitations. 1.856-3 Definitions. 1.856-4 Rents from real property. 1.856-5 Interest. 1.856-6 Foreclosure property. 1.856–7 Certain corporations, etc., that are

considered to meet the gross income re

quirements. 1.856-8 Revocation or termination of elec

tion. 1.857-1 Taxation of real estate investment

trusts. 1.857-2 Real estate investment trust taxable

income and net capital gain. 1.857-3 Net income from foreclosure prop

erty. 1.857-4 Tax imposed by reason of the failure

to meet certain source-of-income re

quirements. 1.857–5 Net income and loss from prohibited

transactions. 1.857-6 Method of taxation of shareholders

of real estate investment trusts. 1.857-7 Earnings and profits of a real estate

investment trust. 1.857-8 Records to be kept by a real estate

investment trust. 1.857-9 Information required in returns of

shareholders. 1.857-10 Information returns. 1.857–11 Non-REIT earnings and profits. 1.858-1 Dividends paid by a real estate in

vestment trust after close of taxable

year. 1.860-1 Deficiency dividends. 1.860-2 Requirements for deficiency divi

dends. 1.860-3 Interest and additions to tax. 1.860–4 Claim for credit or refund. 1.860-5 Effective date. 1.860A-0 Outline of REMIC provisions. 1.860A-1 Effective dates and transition

rules. 1.860C-1 Taxation of holders of residual in

terests. 1.860C-2 Determination of REMIC taxable

income or net loss. 1.860D-1 Definition of a REMIC. 1.860E-1 Treatment of taxable income of a

residual interest holder in excess of daily

accruals. 1.860E-2 Tax on transfers of residual inter

ests to certain organizations. 1.860F-1 Qualified liquidations. 1.860F-2 Transfers to a REMIC. 1.860F-4 REMIC reporting requirements and

other administrative rules.
1.860G-1 Definition of regular and residual

interests.
1.860G-2 Other rules.
1.860G-3 Treatment of foreign persons.

included.

DETERMINATION OF SOURCES OF INCOME 1.861–1 Income from sources within the

United States. 1.861-2 Interest. 1.861-3 Dividends. 1.861-4. Compensation for labor or personal

services. 1.861-5 Rentals and royalties. 1.861-6 Sale of real property. 1.861–7 Sale of personal property. 1.861–8 Computation of taxable income from

sources within the United States and

from other sources and activities. 1.861-8T Computation of taxable income

from sources within the United States and from other sources and activities

(temporary). 1.861-9 Allocation and apportionment of in

terest expense. 1.861-9T Allocation and apportionment of

interest expense (temporary regula

tions). 1.861-10 Special allocations of interest ex

pense. 1.861-10T Special allocations of interest ex

pense (temporary regulations). 1.861-11 Special rules for allocating and ap

portioning interest expense of an affili

ated group of corporations. 1.861-11T Special rules for allocating and

apportioning interest expense of an affiliated group of corporations (temporary

regulations). 1.861-12T Characterization rules and adjust

ments for certain assets (temporary reg

ulations). 1.861-13T Transition rules for interest ex

penses (temporary regulations). 1.861-14 Special rules for allocating and ap

portioning certain expenses (other than interest expense) of an affiliated group of

corporations. 1.861-14T Special rules for allocating and

apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary regula

tions). 1.861–15 Income from certain aircraft or ves

sels first leased on or before December 28,

1980. 1.861-16 Income from certain craft first

leased after December 28, 1980. 1.861-17 Allocation and apportionment of re

search and experimental expenditures. 1.861-18 Classification of transactions in

volving computer programs. 1.862-1 Income specifically from sources

without the United States. 1.863-0 Table of contents. 1.863-1 Allocation of gross income under

section 863(a). 1.863—2 Allocation and apportionment of

taxable income.

1.863.3 Allocation and apportionment of in

come from certain sales of inventory. REGULATIONS APPLICABLE TO TAXABLE YEARS

PRIOR TO DECEMBER 30, 1996 1.863-3A Income from the sale of personal

property derived partly from within and

partly from without the United States. 1.863-3AT Income from the sale of personal

property derived partly from within and partly from without the United States

(temporary regulations). 1.863 4. Certain transportation services. 1.863-6 Income from sources within a for

eign country or possession of the United

States. 1.863-7 Allocation of income attributable to

certain notional principal contracts

under section 863(a). 1.864-1 Meaning of sale, etc. 1.864-2 Trade or business within the United

States. 1.864–3 Rules for determining income effec

tively connected with U.S. business of nonresident aliens or foreign corpora

tions. 1.8644 U.S. source income effectively con

nected with U.S. business. 1.864–5 Foreign source income effectively

connected with U.S. business. 1.864–6 Income, gain, or loss attributable to

an office or other fixed place of business

in the United States. 1.864–7 Definition of office or other fixed

place of business. 1.864-8T Treatment of related person fac

toring income (temporary). 1.865–1T Loss with respect to personal prop

erty other than stock (temporary). 1.865-2 Loss with respect to stock. 1.865–2T Loss with respect to stock (tem

porary).

NONRESIDENT ALIENS AND FOREIGN

CORPORATIONS

NONRESIDENT ALIEN INDIVIDUALS

1.871-1 Classification and manner of taxing

alien individuals. 1.871–2 Determining residence of alien indi

viduals. 1.871-3 Residence of alien seamen. 1.871-4 Proof of residence of aliens. 1.871-5 Loss of residence by an alien. 1.871-6 Duty of withholding agent to deter

mine status of alien payees. 1.871-7 Taxation of nonresident alien indi

viduals not engaged in U.S. business. 1.871-8 Taxation of nonresident alien indi

viduals engaged in U.S. business or treated as having effectively connected in

come. 1.871-9 Nonresident alien students or train

ees deemed to be engaged in U.S. business.

1.884–5 Qualified resident.

MISCELLANEOUS PROVISIONS

1.871-10 Election to treat real property in

come as effectively connected with U.S.

business. 1.871-11 Gains from sale or exchange of pat

ents, copyrights, or similar property. 1.871–12 Determination of tax on treaty in

come. 1.871-13 Taxation of individuals for taxable

year of change of U.S. citizenship or resi

dence. 1.871-14 Rules relating to repeal of tax on

interest of nonresident alien individuals and foreign corporations received from

certain portfolio debt investments. 1.872-1 Gross income of nonresident alien

individuals. 1.872-2 Exclusions from gross income of

nonresident alien individuals. 1.873–1 Deductions allowed nonresident

alien individuals. 1.874-1 Allowance of deductions and credits

to nonresident alien individuals. 1.875-1 Partnerships. 1.875-2 Beneficiaries of estates or trusts. 1.876-1 Alien residents of Puerto Rico. 1.879-1 Treatment of community income.

1.891 Statutory provisions; doubling of rates

of tax on citizens and corporations of

certain foreign countries. 1.892–1T Purpose and scope of regulations

(temporary regulations). 1.892-2T Foreign government defined (tem

porary regulations). 1.892-3T Income of foreign governments

(temporary regulations). 1.892-4T Commercial activities (temporary

regulations). 1.892-5T Controlled commercial entity

(temporary regulations). 1.892–6T Income of international organiza

tions (temporary regulations). 1.892–7T Relationship to other Internal Rev

enue Code sections (temporary regula

tions). 1.893-1 Compensation of employees of for

eign governments or international orga

nizations. 1.894–1 Income affected by treaty. 1.895–1 Income derived by a foreign central

bank of issue, or by Bank for International Settlements, from obligations of the United States or from bank depos

its. 1.897–1 Taxation of foreign investment in

United States real property interests,

definition of terms. 1.897-2 United States real property holding

corporations. 1.897–3 Election by foreign corporation to be

treated as a domestic corporation under

section 897(i). 1.897-4AT Table of contents (temporary). 1.897–5T Corporate distributions (tem

porary). 1.897–6T Nonrecognition exchanges applica

ble to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganiza

tions (temporary). 1.897–7T Treatment of certain partnership

interests as entirely U.S. real property interests under sections 897(g) and 1445(e)

(temporary). 1.897–8T Status as a U.S. real property hold

ing corporation as a condition for electing section 897(i) pursuant to $1.897-3

(temporary). 1.897-9T Treatment of certain interest in

publicly traded corporations, definition of foreign person, and foreign governments and international organizations (temporary).

FOREIGN CORPORATIONS 1.881-0 Table of contents. 1.881-1 Manner of taxing foreign corpora

tions. 1.881-2 Taxation of foreign corporations not

engaged in U.S. business. 1.881-3 Conduit financing arrangements. 1.881-4 Recordkeeping requirements

cerning conduit financing arrangements. 1.882-0 Table of contents. 1.882–1 Taxation of foreign corporations en

gaged in U.S. business or of foreign corporations treated as having effectively

connected income. 1.882-2 Income of foreign corporations

treated as effectively connected with

U.S. business. 1.882-3 Gross income of a foreign corpora

tion. 1.8824 Allowance of deductions and credits

to foreign corporations. 1.882–5 Determination of interest deduction. 1.883-1 Exclusions from gross income of for

eign corporations. 1.8840 Overview of regulation provisions for

section 884. 1.884-1 Branch profits tax. 1.884-2 Special rules for termination or in

corporation of a U.S. trade or business or liquidation or reorganization of a foreign

corporation or its domestic subsidiary. 1.884-2T Special rules for termination or in

corporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary

(temporary). 1.884-3T Coordination of branch profits tax

with second-tier withholding (tem

porary). (Reserved] 1.8844 Branch-level interest tax.

con

INCOME FROM SOURCES WITHOUT THE UNITED

STATES

FOREIGN TAX CREDIT

1.901-1 Allowance of credit for taxes. 1.901-2 Income, war profits, or excess profits

tax paid or accrued.

use

on

1.901-24 Dual capacity taxpayers. 1.901-3 Reduction in amount of foreign

taxes on foreign mineral income allowed

as a credit. 1.902–0 Outline of regulations provisions for

section 902. 1.902–1 Credit for domestic corporate share

holder of a foreign corporation for foreign income taxes paid by the foreign

corporation. 1.902–2 Treatment of deficits in post-1986

undistributed earnings and pre-1987 accumulated profits of a first-, second-, or third-tier corporation for purposes of computing an amount of foreign taxes

deemed paid under $1.902–1. 1.902–3 Credit for domestic corporate share

holder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before

January 1, 1987. 1.902–4 Rules for distributions attributable

to accumulated profits for taxable years in which a first-tier corporation was a

less developed country corporation. 1.903-1 Taxes in lieu of income taxes. 1.904–0 Outline of regulation provisions for

section 904. 1.904-1 Limitation credit for foreign

taxes. 1.904–2 Carryback and carryover of unused

foreign tax. 1.904-3 Carryback and carryover of unused

foreign tax by husband and wife, 1.904–4 Separate application of section 904

with respect to certain categories of in

come. 1.904-5 Look-through rules as applied to

controlled foreign corporations and other

entities. 1.904–6 Allocation and apportionment of

taxes. 1.904-7 Transition rules. 1.904(b)-1 Treatment of capital gains for

corporations. 1.904(0)-2 Treatment of capital gains for

other taxpayers. 1.904(b)-3 Sale of personal property. 1.904(b)-4 Effective date. 1.904(f)-1 Overall foreign loss and the over

all foreign loss account. 1.904(1)-2 Recapture of overall foreign

losses. 1.904(f)-3 Allocation of net operating losses

and net capital losses. 1.904(f)-4 Recapture of foreign losses out of

accumulation distributions from a for

eign trust. 1.904(f)-5 Special rules for recapture of over

all foreign losses of a domestic trust. 1.904(f)6 Transitional rule for recapture of

FORI and general limitation overall foreign losses incurred in taxable years beginning before January 1, 1983, from foreign source taxable income subject to the

general limitation in taxable years be

ginning after December 31, 1982. 1.904(1)-7-1.904(f)-11 (Reserved] 1.904(f)-12 Transition rules. 1.904(i)-1 Limitation on

of deconsolidation to avoid foreign tax

credit limitations. 1.905-1 When credit for taxes may be taken. 1.905-2 Conditions of allowance of credit. 1.905–3T Adjustments to the pools of foreign

taxes and earnings and profits when the allowable foreign tax credit changes

(temporary). 1.905-4T Notification and redetermination

of United States tax liability (tem

porary). 1.905-5T Foreign tax redeterminations and

currency translation rules for foreign tax redeterminations occurring in taxable years beginning prior to January 1, 1987

(temporary). 1.907–0 Outline of regulation provisions for

section 907. 1.907(a)0 Introduction (for taxable years

beginning after December 31, 1982). 1.907(a)-1 Reduction in taxes paid on FOGEI

(for taxable years beginning after De

cember 31, 1982). 1.907(b)-1 Reduction of creditable FORI

taxes (for taxable years beginning after

December 31, 1982). 1.907(C)-1 Definitions relating to FOGEI and

FORI (for taxable years beginning after

December 31, 1982). 1.907(c)-2 Section 907(C)(3) items (for taxable

years beginning after December 31, 1982). 1.907(CH3 FOGEI and FORI taxes (for tax

able years beginning after December 31,

1982). 1.907(d)-1 Disregard of posted prices for pur

poses of chapter 1 the Code (for taxable years beginning after December 31,

1982). 1.907(e)-1 [Reserved). 1.907(f)-1 Carryback and carryover of cred

its disallowed by section 907(a) (for amounts carried between taxable years

that each begin after December 31, 1982). AUTHORITY: 26 U.S.C. 7805. Section 1.852-11 is also issued under 26 U.S.C.

852(b)(3)(C), 852(b)(8), and 852(c). Section 1.860D-1 also issued under 26 U.S.C.

860G(e). Section 1.860E-1 also issued under 26 U.S.C.

860E and 860G(e). Section 1.860E-2 also issued under 26 U.S.C.

860E(e). Section 1.860F-2 also issued under 26 U.S.C.

860G(e). Section 1.860F-4T also issued under 26 U.S.C.

860G(C)(3) and (e). Section 1.860G-1 also issued under 26 U.S.C.

860G(a)(1)(B) and (e). Section 1.860G-3 also issued under 26 U.S.C.

860G(b) and 26 U.S.C. 860G(e). Section 1.861-2 also issued under 26 U.S.C.

863(a).

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