The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1998 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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1.5. rezultāts no 100.
10. lappuse
... controlled foreign corporations begin- ning after December 31 , 1975 , and to taxable years of United States share- holders ( within the meaning of section 951 ( b ) within which or with which such taxable years of such controlled ...
... controlled foreign corporations begin- ning after December 31 , 1975 , and to taxable years of United States share- holders ( within the meaning of section 951 ( b ) within which or with which such taxable years of such controlled ...
11. lappuse
... controlled group , in the securities of such issuer . See ex- ample 4 in §1.851-5 . For purposes of §§ 1.851-2 , 1.851-4 , 1.851-5 , and 1.851-6 , the terms " controls " , " controlled group " , and value have the meaning assigned ...
... controlled group , in the securities of such issuer . See ex- ample 4 in §1.851-5 . For purposes of §§ 1.851-2 , 1.851-4 , 1.851-5 , and 1.851-6 , the terms " controls " , " controlled group " , and value have the meaning assigned ...
12. lappuse
... controlled group . Invest- ment Company W meets the requirements under section 851 ( b ) ( 4 ) at the end of its ... controlled group , Y - K - L - B ( 40 percent of 20 percent of 30 per- cent ) 20.0 2.4 Percentage invested in the ...
... controlled group . Invest- ment Company W meets the requirements under section 851 ( b ) ( 4 ) at the end of its ... controlled group , Y - K - L - B ( 40 percent of 20 percent of 30 per- cent ) 20.0 2.4 Percentage invested in the ...
146. lappuse
... controlled foreign corpora- tion " properly allocable to such in- come " . This section provides rules for identifying which deductions are prop- erly allocable to foreign base company income . ( vi ) Other operative sections . The ...
... controlled foreign corpora- tion " properly allocable to such in- come " . This section provides rules for identifying which deductions are prop- erly allocable to foreign base company income . ( vi ) Other operative sections . The ...
154. lappuse
... controlled foreign corporations ( " CFCs " ) ( as defined in section 957 ( a ) of the Code ) which derive exclusively foreign source general limitation income . X owns stock representing 10 to 50 percent of the vote and value in such ...
... controlled foreign corporations ( " CFCs " ) ( as defined in section 957 ( a ) of the Code ) which derive exclusively foreign source general limitation income . X owns stock representing 10 to 50 percent of the vote and value in such ...
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Bieži izmantoti vārdi un frāzes
adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation country X December 31 deduction described in paragraph determined distribution domestic corporation dual capacity taxpayers earnings and profits effectively connected election entity erty estate investment trust Example fair market value foreign cor foreign corporation foreign country foreign mineral income foreign source foreign tax graph gross income holder income from sources income tax treaty inter interest expense levy liabilities ment mortgage nonresident alien individual paid partnership payment percent poration post-October pursuant qualified real estate investment real property holding real property interest received REMIC resident respect share source income spect statutory grouping subparagraph taxable income taxable years beginning terest tion trade or business transaction transfer treated U.S. assets U.S. dollars U.S. real property U.S. shareholder U.S. source U.S. tax unit investment trust United X tax
Populāri fragmenti
472. lappuse - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.
122. lappuse - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income.
267. lappuse - Gains, profits and income from (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within...
542. lappuse - States, whether resident or nonresident, may claim a credit for (i) the amount of any income, war profits, and excess profits taxes paid or accrued (or deemed paid or accrued under section 905(b)) during- the taxable year to any foreign country or to any possession of the United States: and (ii) his share of any such taxes of a partnership of which he is a member.
340. lappuse - In the case of a nonresident alien individual the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States; and the proper apportionment and allocation of the deductions with respect to sources of income within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary.
376. lappuse - Persons entitled to the benefits of this section shall not be allowed the credits against the tax for taxes of foreign countries and possessions of the United States allowed by section 901.
289. lappuse - Rentals or royalties from property located In the United States or from any Interest In such property, Including rentals or royalties for the use of or for the privilege of using In the United States, patents, copyrights, secret processes and formulas, good will, trademarks, trade brands, franchises, and other like property; and (5) Sale of real property.
82. lappuse - ... is greater than the excess of the net long-term capital gain over the net short-term capital loss of the taxable year, the portion of each distribution which shall be a capital gain dividend shall be only that proportion of the amount so designated which such excess of the net long-term capital gain over the net short-term capital loss bears to the aggregate amount so designated.
273. lappuse - States if (A) the labor or services are performed by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year...
136. lappuse - States as provided in subsection (a) (2) of this section; (3) Compensation for labor or personal services performed without the United States; (4) Rentals or royalties from property located without the United States or from any interest in such property...