Taxable Years Sec. 231. (b) Resident corporations. A foreign corporation engaged in trade or business within the United States shall be taxable as provided in section 14 (c) (1) and section 15. Sec. 231 (b), I. R. C., supra, amended by Sec. 160 (d), R. A. of 1942, to read as above. Sec. 101 of said Act made amendment applicable to taxable years beginning after Dec. 31, 1941. For Sec. 231 (b), I. R. C., before amendment, see 1942 column. Sec. 231. (c) Gross income.-In Taxable Years omitting language "and not Sec. 231. (b) Resident corporations. A foreign corporation engaged in trade or business within the United States or having an of fice or place of business therein shall be taxable as provided in section 14 (c) (1) and section 15. Sec. 231 (b), I. R. C., supra, amended by Sec. 160 (d), R. A. of 1942, by omitting language in stricken through type. Sec. 101 of said Act made amendment applicable to taxable years beginning after Dec. 31, 1941. For prior amendments, see Sec. 231 (b), I. R. C., in 1941 column. Sec. 231. (c) Gross income.-In Sec. 231. (b) Resident corporations. A foreign corporation engaged in trade or business within the United States or having an office or place of business therein shall be taxable as provided in section 14 (c) (1) and section 15. Sec. 231 (b), I. R. C., supra, amended by Sec. 104 (d), R. A. of 1941, by adding language in italics. Sec. 118 of said Act made amendment applicable to taxable years beginning after Dec. 31, 1940. For prior amendments, see Sec. 231 (b), I. R. C., in 1940 column. Sec. 231. (c) Gross income.-In the case of a foreign corporation the case of a foreign corporation the case of a foreign corporation gross income includes only the gross income includes only the gross income includes only the gross income from sources within gross income from sources within the United States. the United States. gross income from sources within the United States. Sec. 231. (d) Ships under for- Sec. 231. (d) Ships under for- Sec. 231. (d) Ships under foreign flag. The income of a foreign flag.-The income of a foreign flag. The income of a foreign corporation, which consists eign corporation, which consists eign corporation, which consists exclusively of earnings derived exclusively of earnings derived exclusively of earnings derived from the operation of a ship or from the operation of a ship or from the operation of a ship or ships documented under the laws ships documented under the laws ships documented under the laws of a foreign country which grants of a foreign country which grants of a foreign country which grants an equivalent exemption to citi- an equivalent exemption to citi- an equivalent exemption to citizens of the United States and to zens of the United States and to zens of the United States and to corporations organized in the corporations organized the corporations organized in United States, shall not be included United States, shall not be included United States, shall not be included in gross income and shall be exgross income and shall be ex- in gross income and shall be exfrom taxation under this empt from taxation under this empt from taxation under this chapter. chapter. Sec. 232. Deductions. in empt Sec. 232. Deductions. in Sec. 232. Deductions. Sec. 232. (a) In general.-In the Sec. 232. (a) In general.-In the Sec. 232. (a) In general.—In the case of a foreign corporation the case of a foreign corporation the case of a foreign corporation the deductions shall be allowed only deductions shall be allowed only deductions shall be allowed only if and to the extent that they are if and to the extent that they are if and to the extent that they are connected with income from connected with income from connected with income from sources within the United States; sources within the United States; sources within the United States; and the proper apportionment and and the proper apportionment and and the proper apportionment and allocation of the deductions with allocation of the deductions with allocation of the deductions with respect to sources within and with- respect to sources within and with- respect to sources within and without the United States shall be de-out the United States shall be de-out the United States shall be determined as provided in section termined as provided in section termined as provided in section 119, under rules and regulations 119, under rules and regulations 119, under rules and regulations prescribed by the Commissioner prescribed by the Commissioner prescribed by the Commissioner with the approval of the Secre- with the approval of the Secre- with the approval of the Secretary. tary. tary. Sec. 232. (b) Charitable, and so Sec. 232. (b) Charitable, and so Sec. 232. (b) Charitable, and so forth, contributions.-The so-called forth, contributions. The so-called forth, contributions. The so-called "charitable contribution" deduc- "charitable contribution" deduc-"charitable contribution" deduc Taxable Years Taxable Years Taxable Years Beginning before 1939 Sec. 231. (b) Resident corporations. A foreign corporation engaged in trade or business within the United States or having an office or place of business therein shall be taxable as provided in section 14 (c) (1). Sec. 231 (b), I. R. C., supra, amended by Sec. 206, R. A. of 1939 by substituting "14 (c) (1)" for "14 (e) (1). Sec. 229 of said Act made amendment applicable to taxable years beginning after Dec. 31, 1939. Sec. 231. (b) Resident corpora Sec. 231. (b) Resident corpora- See p. 334, Eighth Edition. Sec. 231. (c) Gross income.-In Sec. 231. (c) Gross income.—In the case of a foreign corporation the case of a foreign corporation gross income includes only the gross income includes only the gross income from sources within gross income from sources within the United States. the United States. Sec. 231. (d) Ships under for- Sec. 231. (d) Ships under foreign flag. The income of a foreign flag.-The income of a foreign corporation, which consists eign corporation, which consists exclusively of earnings derived exclusively of earnings derived from the operation of a ship or from the operation of a ship or ships documented under the laws ships documented under the laws of a foreign country which grants of a foreign country which grants an equivalent exemption to citi- an equivalent exemption to citizens of the United States and to zens of the United States and to corporations organized in the corporations organized in the United States, shall not be included in gross income and shall be exempt from taxation under this chapter. Sec. 232. Deductions. United States, shall not be included Sec. 232. Deductions. Sec. 232. (a) In general.-In the Sec. 232. (a) In general.—In the case of a foreign corporation the case of a foreign corporation the deductions shall be allowed only deductions shall be allowed only if and to the extent that they are if and to the extent that they are connected with income from connected with income from sources within the United States; sources within the United States; and the proper apportionment and and the proper apportionment and allocation of the deductions with allocation of the deductions with respect to sources within and with respect to sources within and without the United States shall be de- out the United States shall be determined as provided in section termined as provided in section 119, under rules and regulations 119, under rules and regulations prescribed by the Commissioner prescribed by the Commissioner with the approval of the Secre- with the approval of the Secretary. tary. Sec. 232. (b) Charitable, and so Sec. 232. (b) Charitable, and so forth, contributions.-The so-called forth, contributions.-The so-called "charitable contribution" deduc-charitable contribution" deduc Sec. 231. (c) Gross income. See p. 334, Eighth Edition. Sec. 231. (d) Ships under foreign flag. See p. 334, Eighth Edition. Sec. 232. Deductions. See p. 334, Eighth Edition. Sec. 232. (b) Charitable, and so forth, contributions. See p. 334, Eighth Edition. Taxable Years Taxable Years Taxable Years tion allowed by section 23 (q) tion allowed by section 23 (q)tion allowed by section 23 (q) shall be allowed whether or not shall be allowed whether or not shall be allowed whether or not connected with income from sources connected with income from sources connected with income from sources within the United States. within the United States. within the United States. Sec. 233. Allowance of deductions and credits. Sec. 233. Allowance of deductions and credits. Sec. 233. Allowance of deductions and credits. A foreign corporation shall re- A foreign corporation shall re- A foreign corporation shall receive the benefit of the deductions ceive the benefit of the deductions ceive the benefit of the deductions and credits allowed to it in this and credits allowed to it in this and credits allowed to it in this chapter only by filing or causing chapter only by filing or causing chapter only by filing or causing to be filed with the collector a true to be filed with the collector a true to be filed with the collector a true and accurate return of its total in- and accurate return of its total in- and accurate return of its total income received from all sources in come received from all sources in come received from all sources in the United States, in the manner the United States, in the manner the United States, in the manner prescribed in this chapter; includ- prescribed in this chapter; includ- prescribed in this chapter; including therein all the information which ing therein all the information ing therein all the information the Commissioner may deem neces- which the Commissioner may deem which the Commissioner may deem sary for the calculation of such de- necessary for the calculation of necessary for the calculation of ductions and credits. such deductions and credits. such deductions and credits. Sec. 235. (a) Time of filing.— In the case of a foreign corporation not having any office or place of business in the United States the return, in lieu of the time prescribed in section 53 (a) (1), shall be made on or before the fifteenth day of the sixth month following the close of the fiscal year, or, if the return is made on the basis of the calendar year then on or before the fifteenth day of June. If any foreign corporation has no office or place of business in the United States but has an agent in the United States, the return shall be made by the agent. Sec. 234. Credits against tax. Sec. 234. Credits against tax. Foreign corporations shall not be Foreign corporations shall not be allowed the credits against the tax allowed the credits against the tax for taxes of foreign countries and for taxes of foreign countries and possessions of the United States possessions of the United States allowed by section 131. A foreign allowed by section 131. A foreign corporation shall be allowed as a corporation shall be allowed as a credit against its tax the amount credit against its tax the amount required by section 396 to be paid required by section 396 to be paid by the personal service corporation by the personal service corporation of which it is a shareholder with of which it is a shareholder with respect to its tax liability under respect to its tax liability under Supplement S. Supplement S. Sec. 235. (a) Time of filing.—In Sec. 235. (a) Time of filing.-In the case of a foreign corporation the case of a foreign corporation not having any office or place of not having any office or place of business in the United States the business in the United States the return, in lieu of the time pre- return, in lieu of the time prescribed in section 53 (a) (1), shall scribed in section 53 (a) (1), shall be made on or before the fifteenth be made on or before the fifteenth day of the sixth month following day of the sixth month following the close of the fiscal year, or, if the close of the fiscal year, or, if the return is made on the basis of the return is made on the basis of the calendar year then on or before the fifteenth day of June. If any foreign corporation has no office or place of business in the United States but has an agent in the United States, the return shall be made by the agent. Sec. 235. (b) Exemption from Sec. 235. (b) Exemption from requirement. Subject to such con- requirement.-Subject to such conditions, limitations, and exceptions ditions, limitations, and exceptions and under such regulations as may and under such regulations as may be prescribed by the Commissioner, be prescribed by the Commissioner, the calendar year then on or before the fifteenth day of June. If any foreign corporation has no office or place of business in the United States but has an agent in the United States, the return shall be made by the agent. Sec. 235. (b) Exemption from requirement.-Subject to such conditions, limitations, and exceptions and under such regulations as may be prescribed by the Commissioner, tion allowed by section 23 (q) tion allowed by section 23 (q) Sec. 233. Allowance of deductions and credits. Sec. 233. Allowance of deductions and credits. A foreign corporation shall re- A foreign corporation shall receive the benefit of the deductions ceive the benefit of the deductions and credits allowed to it in this and credits allowed to it in this chapter only by filing or causing chapter only by filing or causing to be filed with the collector a true to be filed with the collector a true and accurate return of its total in- and accurate return of its total income received from all sources in come received from all sources in the United States, in the manner the United States, in the manner prescribed in this chapter; includ-prescribed in this chapter; including therein all the information ing therein all the information which the Commissioner may deem which the Commissioner may deem necessary for the calculation of necessary for the calculation of such deductions and credits. such deductions and credits. Sec. 234. Credits against tax. Foreign corporations shall not be allowed the credits against the tax for taxes of foreign countries and possessions of the United States allowed by section 131. A foreign corporation shall be allowed as a credit against its tax the amount required by section 396 to be paid by the personal service corporation of which it is a shareholder with respect to its tax liability under Supplement S. Sec. 234, I. R. C., supra, amended by Sec. 505, Second R. A. of 1940, approved Oct. 8, 1940, by adding language in italics. Sec. 235. Returns. Sec. 235. (a) Time of filing.-In Sec. 234. Credits against tax. Foreign corporations shall not be allowed the credits against the tax for taxes of foreign countries and possessions of the United States allowed by section 131. Sec. 235. Returns. Sec. 235. (a) Time of filing.—In the case of a foreign corporation the case of a foreign corporation not having any office or place of not having any office or place of business in the United States the business in the United States the return, in lieu of the time pre- return, in lieu of the time prescribed in section 53 (a) (1), shall scribed in section 53 (a) (1), shall be made on or before the fifteenth be made on or before the fifteenth day of the sixth month following day of the sixth month following the close of the fiscal year, or, the close of the fiscal year, or, if if the return is made on the basis of the return is made on the basis of the calendar year then on or before the calendar year then on or before the fifteenth day of June. If any the fifteenth day of June. If any foreign corporation has no office foreign corporation has no office or place of business in the United or place of business in the United States but has an agent in the States but has an agent in the United States, the return shall be United States, the return shall be made by the agent. made by the agent. Sec. 235. (b) Exemption from Sec. 235. (b) Exemption from requirement. Subject to such con- requirement. Subject to such conditions, limitations, and exceptions ditions, limitations, and exceptions and under such regulations as may and under such regulations as may be prescribed by the Commissioner, be prescribed by the Commissioner, Taxable Years Beginning before 1939 Sec. 233. Allowance of deductions and credits. See p. 336, Eighth Edition. Sec. 234. Credits against tax. Sec. 235. Returns. Sec. 235. (a) Time of filing. Sec. 235. (b) Exemption from requirement. See p. 336, Eighth Edition. Taxable Years with the approval of the Secretary, corporations subject to the tax imposed by section 231 (a) may be exempted from the requirement of filing returns of such tax. Sec. 236. Payment of tax. Sec. 236. (a) Time of payment. -In the case of a foreign corporation not having any office or place of business in the United States the total amount of tax imposed by this chapter shall be paid, in lieu of the time prescribed in section 56 (a), on the fifteenth day of June following the close of the calendar year, or, if the return should be made on the basis of a fiscal year, then on the fifteenth day of the sixth month following the close of the fiscal year. with the approval of the Secretary, with the approval of the Secretary, Sec. 236. (a) Time of payment. Sec. 236. (a) Time of payment. In the case of a foreign corpora--In the case of a foreign corporation not having any office or place tion not having any office or place of business in the United States of business in the United States the total amount of tax imposed by the total amount of tax imposed by this chapter shall be paid, in lieu this chapter shall be paid, in lieu of the time prescribed in section of the time prescribed in section 56 (a), on the fifteenth day of 56 (a), on the fifteenth day of June following the close of the cal- June following the close of the calendar year, or, if the return should endar year, or, if the return should be made on the basis of a fiscal be made on the basis of a fiscal year, then on the fifteenth day of year, then on the fifteenth day of the sixth month following the close the sixth month following the close of the fiscal year. of the fiscal year. Sec. 236. (b) Withholding at source. For withholding at source of tax on income of foreign corporations, see section 144. Sec. 237. Foreign insurance companies. For special provisions relating to foreign insurance companies, see Supplement G. See. 238. Affiliatio A foreign corporation shall not be deemed to be affiliated with any other corporation within the mean ing of section 141. Sec. 238, I. R. C., supra, repealed by Sec. 159 (c), R. A. of 1942. Sec. 101 of said Act makes repeal applicable to taxable years beginning after Dec. 31, 1941. Sec. 236. (b) Withholding at source. For withholding at source of tax on income of foreign corporations, see section 144. Sec. 237. Foreign insurance companies. For special provisions relating to foreign insurance companies, see Supplement G. Sec. 238. Affiliation. A foreign corporation shall not be deemed to be affiliated with any other corporation within the meaning of section 141. Supplement J-Possessions of the Supplement J-Possessions of the Supplement J-Possessions of the United States United States. Sec. 251. Income from sources Sec. 251. Income from sources within possessions of the United within possessions of the United States. States. United States. Sec. 251. Income from sources within possessions of the United States. Sec. 251. (a) General Rule.-In Sec. 251. (a) General rule.-In Sec. 251. (a) General rule.-In the case of citizens of the United the case of citizens of the United the case of citizens of the United States or or domestic corporations, States or domestic corporations, States domestic corporations, satisfying the following conditions, satisfying the following conditions, satisfying the following conditions, gross income means only gross in- gross income means only gross in- gross income means only gross infrom from within the come Sources within the come from United States Sec. 251. (a) (1) If 80 per Sec. 251. (a) (1) If 80 per Sec. 251. (a) (1) If 80 per centum or more of the gross income centum or more of the gross income centum or more of the gross income of such citizen or domestic corpo- of such citizen or domestic corpo- of such citizen or domestic corporation (computed without the bene-ration (computed without the bene-ration (computed without the bene |