 | United States - 1965 - 1110 lapas
...the fraction — (A) the numerator of which Is 14 percent, and (B) the denominator of which is that percentage which equals the sum of the normal tax rate and the surtax rate for the taxable year specified in section 11. Por purposes of the deduction provided in this section,... | |
 | 1978 - 948 lapas
...Ninety percent of an amount determined by multiplying the sum of the consolidated earnings and profits (as determined under paragraph (b)(l) of this section)...(2) Definitions. For purposes of » 1.963-1 through 1.963.8(i) Pro rata minimum distribution. A pro rata minimum distribution from a chain or group for... | |
 | 1977 - 866 lapas
...(b)(l) of this section) and the consolidated foreign income taxes (as determined under paragraph (bXl) of this section) of such chain or group for the taxable...Definitions. For purposes of §§ 1.963-1 through 1.963.8(i) Pro rata minimum distribution. A pro rata minimum distribution from a chain or group for... | |
 | 1970 - 868 lapas
...(1) of this section) and the consolidated foreign income taxes (as determined under paragraph (b) (1) of this section) of such chain or group for the taxable...the shareholder. (2) Definitions. For purposes of §5 1.963-1 through 1.963-7— (i) Pro rata minimum distribution. A pro rata minimum distribution from... | |
 | 1995 - 788 lapas
...§1.963-2) and the consolidated foreign income taxes (as determined under paragraph (e)(2) of §1.963-2) of such chain or group for the taxable year with respect...section 11 for the taxable year of the shareholder, or (ii) With the application of the special rules set forth in paragraphs (b) and (c) of this section—... | |
 | 1966 - 500 lapas
...taxes) for the taxable year of such controlled foreign corporation equals or exceeds 90 percent of a percentage which equals the sum of the normal tax...prescribed by section 11 for the taxable year of the United States shareholder within which or with which ends such taxable year of such controlled foreign... | |
 | 2002 - 804 lapas
...section) and the consolidated foreign income taxes (as determined under paragraph (b)(l) of this section1 of such chain or group for the taxable year with respect...which equals the sum of the normal tax rate and the sartas rate (determined without regard to the surtax exemption) prescribed by section 11 for the taxable... | |
 | 1978 - 952 lapas
...1.963-2) and the consolidated foreign Income taxes (as determined under paragraph (eX2) of § 1.963-2) of such chain or group for the taxable year with respect...percentage which equals the sum of the normal tax rat« and the surtax rate (determined without regard to the surtax exemption) prescribed by section... | |
 | 1990 - 848 lapas
...1976. the highest rate prescribed by section 11 for the taxable year of M Corporation is 48 percent, the sum of the normal tax rate and the surtax rate...(determined without regard to the surtax exemption). Therefore, with respect to the item of interest, there will be considered to have been no substantial... | |
 | 1994 - 780 lapas
...operations. The highest rate prescribed by section 11 for all relevant taxable years is 48 percent, the sum of the normal tax rate and the surtax rate...(determined without regard to the surtax exemption). It is assumed that had Y been incorporated in the United States 26CFRCh. l(4-l-94Edffîon) and owned... | |
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Then multiply the amount determined under paragraph (1) by the fraction — (A) The numerator of which is 14 percent, and (B) The denominator of which is that percentage which equals the sum of the normal tax rate and the surtax rate for the taxable year... 
