Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and Index
Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries.
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able activities adjusted allocated allowed amount apply apportioned apportionment assets attributable base basis beginning branch capital gain Code computed conduct considered controlled debt deduction deemed defined derived described determined disposition distribution dividend earnings and profits effectively connected eign election engaged entity Example excess exchange expense facts fair market value filed foreign corporation foreign tax gain graph gross income held holder holding imposed income tax inter interest interest expense investment levy liability limitation loss meaning ment method paid paragraph partnership payment percent period person portion principal pursuant qualified ration real estate real property interest reason received regulations REMIC resident respect rules securities separate share shareholder solely sources specified Stat statement taxable income taxpayer term tion trade or business transaction treated trust U.S. real property United
370. lappuse - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States shall not be included in gross income and shall be exempt from taxation under this chapter.
292. lappuse - States shall not be deemed to be income from sources within the United 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...
68. lappuse - If the determination of such amount depends in whole or in part on the income or profits derived by any person from such property (except that any amount so received or accrued shall not be excluded from the term "rents from real property...
293. lappuse - engaged In trade or business within the United States" does not Include the effecting of transactions in the United States In stocks or securities through a resident broker, commission agent, custodian, or other independent agent.
144. lappuse - ... there shall be included in the gross income an amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.
90. lappuse - ... 30 days after the close of its taxable year. If the aggregate amount so designated with respect to a taxable year of the...
453. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
349. lappuse - December 31, 1961, compensation paid to a nonresident alien individual for the period that the nonresident alien individual is temporarily present in the United States as a nonimmigrant under subparagraph (F) or (J) of section 101 (a) (15) of the Immigration and Nationality Act...
286. 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 the United States, shall be treated as derived partly from sources within and partly from' sources without the United States.
89. 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.