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CHAPTER I-INTERNAL REVENUE SERVICE,

DEPARTMENT OF THE TREASURY

(Continued)

(Part 1, §§ 1.851 to 1.1200)

SUBCHAPTER A-INCOME TAX (continued)

Part 1

Income tax; taxable years beginning after December 31, 1953 (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)

PART 1-INCOME TAX; TAXABLE YEARS BEGINNING AFTER DECEMBER 31, 1953 (Continued)

Sec.

Normal Taxes and Surtaxes (Continued)

REGULATED INVESTMENT COMPANIES AND REAL ESTATE INVESTMENT TRUSTS

1.851 Statutory provisions; definition of regulated investment company. 1.851-1 Definition of regulated investment company.

1.851-2 Limitations.

1.851-3 Rules applicable to section 851(b)(4).

1.851-4 Determination of status.

1.851-5 Examples.

1.851-6 Investment companies furnishing capital to development corporations. 1.851-7 Certain unit investment trusts.

1.852 Statutory provisions; taxation of regulated investment companies and their shareholders.

1.852-1 Taxation of regulated investment companies.

1.852-2 Method of taxation of regulated investment companies.

1.852-3 Investment company taxable income.

1.852-4 Method of taxation of shareholders of regulated investment companies.

1.852-5 Earnings and profits of a regulated investment company. 1.852-6 Records to be kept for purpose of determining whether a corporation claiming to be a regulated investment company is a personal holding compa

ny.

1.852-7 Additional information required in returns of shareholders.

1.852-8

Information returns.

1.852-9 Special procedural requirements applicable to designation under section 852(b)(3)(D).

1.852-10 Distribution in redemption of interests in unit investment trusts. 1.853 Statutory provisions; foreign tax credit allowed to shareholders.

1.853-1 Foreign tax credit allowed to shareholders.

1.853-2 Effect of election.

1.853-3 Notice to shareholders.

1.853-4 Manner of making election.

1.854 Statutory provisions limitations applicable to dividends received from regulated investment company.

1.854-1 Limitations applicable to dividends received from regulated investment

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1.855 Statutory provisions; dividends paid by regulated investment company after close of taxable year.

1.855-1 Dividends paid by regulated investment company after close of taxable year.

REAL ESTATE INVESTMENT TRUSTS

1.856 Statutory provisions; definition of real estate investment trust.

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1.857 Statutory provisions; taxation of real estate investment trusts and their beneficiaries.

1.857-1 Taxation of real estate investment trusts.

1.857-2

Method of taxation of real estate investment trusts.

1.857-3 Real estate investment trust taxable income.

1.857-4 Method of taxation of shareholders of real estate investment trusts. 1.857-5 Earnings and profits of a real estate investment trust.

1.857-6 Records to be kept by a real estate investment trust.

1.857-7 Information required in returns of shareholders.

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1.858 Statutory provisions; dividends paid by real estate investment trust after close of taxable year.

1.858-1 Dividends paid by real estate investment trust after close of taxable year.

TAX BASED ON INCOME FROM SOURCES WITHIN OR WITHOUT THE UNITED STATES

DETERMINATION OF SOURCES OF INCOME

1.861 Statutory provisions; income from sources within the United States. 1.861-1 Income from sources within the United States.

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1.861-4 Compensation for labor or personal services.

1.861-5 Rentals and royalties.

1.861-6 Sale of real property.

1.861-7 Sale of personal property.

1.861-8 Computation of taxable income from sources within the United States and from other sources and activities.

1.862 Statutory provisions; income from sources without the United States. 1.862-1 Income specifically from sources without the United States. 1.863 Statutory provisions; items not specified in section 861 or 862. 1.863-1 Allocation of gross income under section 863(a).

1.863-2 Income derived partly from sources within and partly from sources without the United States.

1.863-3 Income from the sale of personal property derived partly from within and partly from without the United States.

1.863-4 Transportation service.

1.863-5 Telegraph and cable services.

1.863-6 Income from sources within a foreign country or possession of the United States.

1.864 Statutory provisions; definitions.

1.864-1 Meaning of sale, etc.

1.864-2 Trade or business within the United States.

1.864-3 Rules for determining income effectively connected with U.S. business of nonresident aliens or foreign corporations.

1.864-4 U.S. source income effectively connected with U.S. business.

1.864-5 Foreign source income effectively connected with U.S. business.

1.864-6 Income, gain, or loss attributable to an office or other fixed place of business in the United States.

1.864-7 Definition of office or other fixed place of business.

NONRESIDENT ALIENS AND FOREIGN CORPORATIONS

NONRESIDENT ALIEN INDIVIDUALS

1.871A Statutory provisions, tax on nonresident alien individuals (before amendment by Foreign Investors Tax Act of 1966).

1.871 Statutory provisions; tax on nonresident alien individuals (after amendment by Foreign Investment Tax Act of 1966).

1.871-1

Classification and manner of taxing alien individuals.

1.871-2 Determining residence of alien individuals.

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1.871-4 Proof of residence of aliens.

1.871-5 Loss of residence by an alien.

1.871-6 Duty of employer to determine status of alien employees.

1.871-7 Tax on nonresident alien individuals not engaged in U.S. business.

1.871-8 Taxation of nonresident alien individuals engaged in U.S. business or treated as having effectively connected income.

1.871-9 Nonresident alien students or trainees deemed to be engaged in U.S.

business.

1.871-10 Election to treat real property income as effectively connected with U.S. business.

1.871-11 Gains from sale or exchange of patents, copyrights, or similar property.

1.871-12 Determination of tax on treaty income.

1.871-13 Taxation of individuals for taxable year of change of U.S. citizenship or residence.

1.872 Statutory provisions; gross income.

1.872-1 Gross income of nonresident alien individuals.

1.872-2 Exclusions from gross income of nonresident alien individuals.

1.873 Statutory provisions; deductions.

1.873-1 Deductions allowed nonresident alien individuals.

1.874 Statutory provisions; allowance of deductions and credits.

1.874-1 Allowances of deductions and credits to nonresident alien individuals. 1.875 Statutory provisions; partnerships.

1.875-1 Partnerships.

1.875-2 Beneficiaries of estates or trusts.

1.876 Statutory provisions; alien residents of Puerto Rico.

1.876-1 Alien residents of Puerto Rico.

1.877 Statutory provisions; expatriation to avoid tax.

1.878 Statutory provisions; certain foreign exempt organizations.

FOREIGN CORPORATIONS

1.881 Statutory provisions; tax on income of foreign corporations connected with United States business.

1.881-1 Manner of taxing foreign corporations.

1.881-2 Taxation of foreign corporations not engaged in U.S. business.

1.882 Statutory provisions; tax on income of foreign corporations connected with United States business.

1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected income.

1.882-2 Income of foreign corporations treated as effectively connected with U.S. business.

1.882-3 Gross income of a foreign corporation.

1.882-4 Allowance of deductions to foreign corporations.

1.883 Statutory provisions; exclusions from gross income.

1.833-1 Exclusions from gross income of foreign corporations. 1.884 Statutory provisions; cross references.

MISCELLANEOUS PROVISIONS

1.892 Statutory provisions; doubling of rates of tax on citizens and corporations of certain foreign countries.

1.892 Statutory provisions; income of foreign governments and of international organizations.

1.892-1 Income of foreign governments and international organizations.

1.893 Statutory provisions; compensation of employees of foreign governments or international organizations.

1.893-1 Compensation of employees of foreign governments or international or

ganizations.

1.894 Statutory provisions; income affected by treaty.

1.894-1 Income affected by treaty.

1.895 Statutory provisions; income derived by a foreign central bank of issue from obligations of the United States or from bank deposits.

1.895-1 Income derived by a foreign central bank of issue, or by Bank for international Settlements, from obligations of the United States or from bank deposits.

1.896 Statutory provisions; adjustment of tax on nationals, residents, and corporations of certain foreign countries.

INCOME FROM SOURCES WITHOUT THE UNITED STATES

FOREIGN TAX CREDIT

1.901 Statutory provisions; taxes of foreign countries and of possessions of the United States.

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1.901-3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit.

1.902 Statutory provisions; credit for corporate stockholder in foreign corporation.

1.902-1 Credit for domestic corporate shareholder of a foreign corporation (before amendment by Revenue Act of 1962).

1.902-2 Special rules for payments from certain wholly-owned foreign corporations (before amendment by Revenue Act of 1962).

1.902-3 Credit for domestic corporate shareholder of a foreign corporation (after amendment by Revenue Act of 1962).

1.902-4 Definition of less developed country corporation for purposes of section 902.

1.902-5 Effective dates for the application of section 902 (as amended by Revenue Act of 1962).

1.903 Statutory provisions; credit for taxes in lieu of income, etc., taxes.

1.903-1 Definition of taxes in lieu of income, war profits, or excess profits taxes.

1.904 Statutory provisions; limitation on credit.

1.904-1 Limitation on credit for foreign taxes.

1.904-2 Carryback and carryover of unused foreign tax.

1.904-3 Carryback and carryover of unused foreign tax by husband and wife. 1.904-4 Separate limitation for section 904 interest.

1.905 Statutory provisions; applicable rules.

1.905-1 When credit for taxes may be taken.

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1.905-3 Redetermination of the tax when credit proves incorrect. 1.905-4 Credit for taxes accrued but not paid.

1.905-5 Credit for United Kingdom income taxes paid with respect to royalties.

EARNED INCOME OF CITIZENS OF UNITED STATES

1.911 Statutory provisions; earned income from sources without the United

States.

1.911-1 Earned income from sources without the United States attributable to services performed before 1963.

1.911-2 Earned income from sources without the United States attributable to services performed after 1962.

1.912 Statutory provisions; exemption for certain allowances.

1.912-1 Exclusion of certain cost-of-living allowances.

1.912-2 Exclusion of certain allowances of Foreign Service personnel.

WESTERN HEMISPHERE TRADE CORPORATIONS

1.921 Statutory provisions; definition of Western Hemisphere trade corporations.

1.921-1 Definition of Western Hemisphere trade corporation.

1.922 Statutory provisions; special deduction.

1.922-1 Special deduction of Western Hemisphere trade corporation.

POSSESSIONS OF THE UNITED STATES

1.931 Statutory provisions; income from sources within possessions of the United States.

1.931-1 Citizens of the United States and domestic corporations deriving income from sources within a possession of the United States.

1.932 Statutory provisions; taxation of citizens of possessions of the United

States.

1.932-1 Status of citizens of U.S. possessions.

1.933 Statutory provisions; income from sources within Puerto Rico.

1.933-1 Exclusion of certain income from sources within Puerto Rico.

1.934 Statutory provisions; limitation on reduction in income tax liability incurred to the Virgin Islands.

1.934-1 Limitation on reduction in income tax liability incurred to the Virgin Islands.

1.935 Statutory provisions; coordination of United States and Guam individual income taxes.

1.935-1 Coordination of U.S. and Guam individual income taxes.

CHINA TRADE ACT CORPORATIONS

1.941 Statutory provisions; special deduction for China Trade Act corporations. 1.941-1 Special deduction for China Trade Act corporations.

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