Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1986 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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activities allocable apply apportioned apportionment assets base company shipping basis capital gain carryback company shipping income computed controlled foreign corporation corporation's country X December 31 deduction DISC dividends domestic corporation dual capacity taxpayers earnings and profits effectively connected election Example excess limitation expenses fair market value filed foreign base company foreign country foreign income taxes foreign mineral income foreign tax credit graph gross income income derived income from sources Internal Revenue Code less developed countries levy liability ment nonresident alien individual paid or accrued paragraph percent period poration property holding corporation purposes of section pursuant qualified investments real property holding real property interest residual grouping respect rules spect statutory grouping subdivision subparagraph subpart F income taxable income taxable years beginning taxes deemed paid taxes paid tion trade or business transaction treated U.S. real property U.S. tax unused foreign tax X tax
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70. 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.
187. 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...
261. lappuse - In the case of an alien resident of the United States, the amount of any such taxes paid or accrued during the taxable year to any foreign country, if the foreign country of which such alien resident is a citizen or subject, in imposing such taxes, allows a similar credit to citizens of the United States residing in such country; and (4) PARTNERSHIPS AND ESTATES.
83. lappuse - 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...
83. lappuse - States, shall be treated as derived partly from sources within and partly from sources without the United States.
234. 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.
130. 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...
210. lappuse - ... (c) INCOME OF FOREIGN GOVERNMENTS AND OF INTERNATIONAL ORGANIZATIONS.— The income of foreign governments or international organizations received from investments in the United States in stocks, bonds, or other domestic securities, owned by such foreign governments or...
426. 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...
530. 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.