The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1992 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 44.
38. lappuse
... FSC incorporated in a posses- sion . Q - 2 : Where does a FSC which is in- corporated in a U.S. possession file its ... FSC's taxable year . Thus , for example , assume that for 1985 a FSC adopts a calendar year period as its annual ac ...
... FSC incorporated in a posses- sion . Q - 2 : Where does a FSC which is in- corporated in a U.S. possession file its ... FSC's taxable year . Thus , for example , assume that for 1985 a FSC adopts a calendar year period as its annual ac ...
40. lappuse
... FSC requirements under section 922 are satisfied . Howev- er , such taxpayer need not satisfy the activities test ... FSC's profit under section 925 but are treat- ed for section 925 ( c ) purposes as if they were performed on behalf ...
... FSC requirements under section 922 are satisfied . Howev- er , such taxpayer need not satisfy the activities test ... FSC's profit under section 925 but are treat- ed for section 925 ( c ) purposes as if they were performed on behalf ...
43. lappuse
... FSC ? A - 4 . Under section 924 ( b ) ( 2 ) , a small FSC need not meet the foreign man- agement and economic ... FSC's ) taxable year and election will terminate as of the day preceding the date the target small FSC and acquiring ...
... FSC ? A - 4 . Under section 924 ( b ) ( 2 ) , a small FSC need not meet the foreign man- agement and economic ... FSC's ) taxable year and election will terminate as of the day preceding the date the target small FSC and acquiring ...
44. lappuse
... FSC attributable to foreign trading gross receipts . It includes both the profits earned by the FSC itself from ... FSC's income to the following five categories : ( i ) Exempt foreign trade income de- termined under section 923 and ...
... FSC attributable to foreign trading gross receipts . It includes both the profits earned by the FSC itself from ... FSC's income to the following five categories : ( i ) Exempt foreign trade income de- termined under section 923 and ...
45. lappuse
... FSC's non- exempt foreign trade income with re- spect to a transaction or group of transactions will be treated as United States source income which is effec- tively connected with the FSC's trade or business which is conducted through ...
... FSC's non- exempt foreign trade income with re- spect to a transaction or group of transactions will be treated as United States source income which is effec- tively connected with the FSC's trade or business which is conducted through ...
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Bieži izmantoti vārdi un frāzes
951 with respect 988 transaction administrative pricing allocated apply attributable base company income base company shipping class of stock cluded combined taxable income company shipping income company shipping operations computed contract controlled foreign corporation Corporation's gross income December 31 deduction determined dividend dollar domestic corporation earnings and profits eign corporation election Example exchange gain excluded export property foreign base company foreign country foreign income tax foreign personal holding foreign tax credit FSC's functional currency gain or loss graph income under section lease less developed countries ment minimum distribution payment percent period poration possessions corporation purposes of section qualified investments rata share received related person related supplier rules section 951 small FSC spect spot rate subdivision subparagraph subpart F income taxable year beginning taxes paid tion trade or business transaction transfer price treated trolled foreign corporation U.S. dollar United States dollar United States shareholder
Populāri fragmenti
120. lappuse - It is the policy of the United States to use export controls (A) to the extent necessary to protect the domestic economy from the excessive drain of scarce materials and to reduce the serious inflationary impact of abnormal foreign demand...
201. lappuse - That such distribution has been made to or for the benefit of such persons in proportion to the par value of the shares of stock of the corporation owned by each; except that if the corporation has more than one class of stock, the...
132. 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...
332. lappuse - In other property, (1) out of its earnings or profits accumulated after February 28, 1913, or (2) out of the earnings or profits of the taxable year (computed as of the close of the taxable year without diminution by reason of any distributions made during the taxable year), without regard to the amount of the earnings and profits at the time the distribution was made.
259. lappuse - ... securities and sells them to customers with a view to the gains and profits that may be derived therefrom.
138. lappuse - States— (1) If 80 per centum or more of the gross income of such citizen or domestic corporation (computed without the benefit of this section) for the three-year period immediately preceding the close of the taxable year (or for such part of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States...
249. lappuse - ... as foreign personal holding company income, foreign base company sales income, foreign base company services income, foreign base company shipping income, or foreign base company oil related income.
270. lappuse - This paragraph shall not apply to gains by a producer, processor, merchant, or handler of the commodity which arise out of bona fide hedging transactions reasonably necessary to the conduct of its business in the manner in which such business is customarily and usually conducted by others.
355. lappuse - ... under subpart E of part I of subchapter J (relating to grantors and others treated as substantial owners) shall be considered as...
131. lappuse - States ; and (2) if 90 percent or more of its gross income for such period or such part thereof was derived from the active conduct of a trade or business.