« iepriekšējāTurpināt »
CHAPTER I-INTERNAL REVENUE SERVICE,
DEPARTMENT OF THE TREASURY
(Part 1, §§1.908 to 1.1000)
EDITORIAL NOTE: IRS published a document at 45 FR 6088, Jan. 25, 1980, deleting statutory sections from their regulations. In Chapter I cross-references to the deleted material have been changed to the corresponding sections of the IRS Code of 1954 or to the appropriate regulations sections. When either such change produced a redundancy, the cross-reference has been deleted. For further explanation, see 45 FR 20795, March 31, 1980.
SUBCHAPTER A-INCOME TAX (continued)
Income taxes (continued)
SUPPLEMENTARY PUBLICATIONS: Internal Revenue Service Looseleaf Regulations System. Additional supplementary publications are issued covering Alcohol and Tobacco Tax Regulations and Regulations Under Tax Conventions.
SUBCHAPTER A-INCOME TAX (Continued)
EARNED INCOME OF CITIZENS OF UNITED STATES 1.912-1 Exclusion of certain cost-of-living allowances.
1.912-2 Exclusion of certain allowances of Foreign Service personnel. 1.921-1T Temporary regulations providing transition rules for DISCS and FSCs. 1.921-2 Foreign Sales Corporation-general rules.
1.921-3T Temporary regulations; Foreign Sales Corporation general rules. 1.922-1 Requirements that a corporation
must satisfy to be a FSC or a small FSC. 1.923-1T Temporary regulations; exempt foreign trade income.
1.924(a)-1T Temporary regulations; definition of foreign trading gross receipts. 1.924(c) -1 Requirement that a FSC be managed outside the United States. 1.924(d) -1 Requirement that economic processes take place outside the United States.
1.924(e)-1 Activities relating to the disposition of export property.
1.925(a)-1T Temporary regulations; transfer pricing rules for FSCs. 1.925(b)-1T Temporary regulations; ginal costing rules.
1.927(a)-1T Temporary regulations; definition of export property.
1.927(b)-1T Temporary regulations; definition of gross receipts.
1.927(d)-1 Other definitions.
1.927(d)-2T Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.
1.927(e)-1 Special sourcing rule.
1.927(e)-2T Temporary regulations; effect of boycott participation on FSC and small FSC benefits.
1.927(f)-1 Election and termination of status as a Foreign Sales Corporation.
1.936-4 Intangible property income in the absence of an election out. 1.936-5 Intangible property income when an election out is made: Product, business presence, and contract manufacturing. 1.936-6 Intangible property income when an election out is made: cost sharing and profit split options; covered intangibles. 1.936-7 Manner of making election under section 936 (h)(5); special election for export sales; revocation of election under section 936(a).
1.936-8T Qualified possession source investment income (temporary). [Reserved] 1.936-9T Source of qualified possession source investment income (temporary). [Reserved]
1.936-10 Qualified investments.
CHINA TRADE ACT CORPORATIONS
1.941-1 Special deduction for China Trade Act corporations.
1.941-2 Meaning of terms used in connection with China Trade Act corporations. 1.941-3 Illustration of principles.
1.943-1 Withholding by a China Trade Act corporation.
CONTROLLED FOREIGN CORPORATIONS
1.926(a)-1 Distributions to shareholders. 1.926(a)-1T Temporary regulations; distributions to shareholders.
1.951-1 Amounts included in gross income of United States shareholders.
1.951-2 Coordination of subpart F with election of a foreign investment company to distribute income.
1.951-3 Coordination of subpart F with foreign personal holding company provisions.
1.952-1 Subpart F income defined. 1.952-2 Determination of gross income and taxable income of a foreign corporation. 1.953-1 Income from insurance of United States risks.
1.953-2 Actual United States risks.
1.953-3 Risks deemed to be United States risks.
1.953 4 Taxable income to which section 953 applies.
1.953-5 Corporations not qualifying as insurance companies.
1.953-6 Relationship of sections 953 and 954. 1.954-0 Introduction.
1.954-1 Foreign base company income. 1.954-2 Foreign personal holding company
1.954-3 Foreign base company sales income. 1.954-4 Foreign base company services in
1.954-5 Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976. 1.954-6 Foreign base company shipping in
1.954-7 Increase in qualified investments in foreign base company shipping operations.
1.954-8 Foreign base company oil related in
1.955-0 Effective dates.
1.955-1 Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
1.955-2 Amount of a controlled foreign cor
poration's qualified investments in less developed countries.
1.955-3 Election as to date of determining qualified investments in less developed countries.
1.955 4 Definition of less developed country. 1.955-5 Definition of less developed country corporation.
1.955-6 Gross income from sources within less developed countries. 1.955A-1 Shareholder's pro rata share of
amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
1.955A-2 Amount of a controlled foreign cor
poration's qualified investments in foreign base company shipping operations. 1.955A-3 Election as to qualified investments by related persons. 1.955A-4 Election as to date of determining qualified investment in foreign base company shipping operations.
United States persons of previously taxed earning and profits. 1.959-2 Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
1.959-3 Allocation of distributions to earnings and profits of foreign corporations. 1.959 4 Distributions to United States persons not counting as dividends. 1.960-1 Foreign tax credit with respect to taxes paid on earnings and profits of controlled foreign corporations.
1.960-2 Interrelation of section 902 and section 960 when dividends are paid by third, second-, or first-tier corporation. 1.960-3 Gross-up of amounts included in income under section 951.
1.960 4 Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
1.960-5 Credit for taxable year of inclusion binding for taxable year of exclusion.
1.960-6 Overpayments resulting from increase in limitation for taxable year of exclusion.
1.960-7 Effective dates.
1.961-1 Increase in basis of stock in controlled foreign corporations and of other property.
1.961-2 Reduction in basis of stock in for
eign corporations and of other property. 1.962-1 Limitation of tax for individuals on amounts included in gross income under section 951(a).
1.962-2 Election of limitation of tax for indi
1.962-3 Treatment of actual distributions. 1.962-4 Transitional rules for certain taxable years.
1.963-0 Repeal of section 963; effective dates.
1.963-1 Exclusion of subpart F income upon receipt of minimum distribution. 1.963-2 Determination of the amount of the
1.963-3 Distributions counting toward a
1.963-4 Limitations on minimum distribution from a chain or group.
1.963-5 Foreign corporations with variation in foreign tax rate because of distributions.
1.963-6 Deficiency distribution.
1.963-7 Transitional rules for certain taxable years.
1.963-8 Determination of minimum distribution during the surcharge period. 1.964-1 Determination of the earnings and profits of a foreign corporation. 1.964-1T Special rules for computing earn
ings and profits of controlled foreign corporations in taxable years beginning after December 31, 1986 (temporary). 1.964-2 Treatment of blocked earnings and profits.
1.964-3 Records to be provided by United States shareholders.
1.964 4 Verification of certain classes of income.
1.964-5 Effective date of subpart F.
EXPORT TRADE CORPORATIONS
1.970-1 Export trade corporations.
1.970-2 Elections as to date of determining investments in export trade assets. 1.970-3 Effective date of subpart G. 1.971-1 Definitions with respect to export trade corporations.
1.972-1 Consolidation of group of export trade corporations. 1.981-0 Repeal of section 981; effective dates. 1.981-1 Foreign law community income for taxable years beginning after December 31, 1966, and before January 1, 1977. 1.981-2 Foreign law community income for taxable years beginning before January 1, 1967.
1.981-3 Definitions and other special rules. 1.985-0 Outline of regulation. 1.985-1 Functional currency.
1.985-2 Election to use the United States dollar as the functional currency of a QBU.
1.985-3 United States dollar approximate separate transactions method.
1.985 4 Method of accounting. 1.985-5 Adjustments required upon change in functional currency.
1.985-6 Transition rules for a QBU that uses the dollar approximate separate transactions method for its first taxable year beginning in 1987.
1.985-7 Adjustments required in connection with a change to DASTM. 1.985-8T Special rules applicable to the European Monetary Union (conversion to the euro) (temporary).
1.987-1 Profit and loss method of accounting for a qualified business unit of a taxpayer having a different functional currency from the taxpayer. [Reserved] 1.987-2 Accounting for gain or loss on certain transfers of property. [Reserved] 1.987-3 Termination. [Reserved] 1.987-4 Special rules relating to QBU branches of foreign taxpayers. [Reserved] 1.987-5 Transition rules for certain qualified business units using a profit and loss method of accounting for taxable years beginning before January 1, 1987. 1.988-0 Taxation of gain or loss from a section 988 transaction; table of contents. 1.988-1 Certain definitions and special rules. 1.988-2 Recognition and computation of exchange gain or loss.
1.988-3 Character of exchange gain or loss. 1.988-4 Source of gain or loss realized on a section 988 transaction.
1.988-5 Section 988(d) hedging transactions. 1.989(a)-1 Definition of a qualified business unit.
1.989(b)-1 Definition of weighted average exchange rate.
1.989(c)-1 Transition rules for certain branches of United States persons using a net worth method of accounting for taxable years beginning before January 1, 1987.