1.941-2 Meaning of terms used in connection with China Trade Act corporations.

1.941-3 Illustration of principles.

1.942 Statutory provisions; disallowance of foreign tax credit.

1.943 Statutory provisions; exclusion of dividends to residents of Formosa or Hong Kong.

1.943-1 Withholding by a China Trade Act corporation.

CONTROLLED FOREIGN CORPORATIONS

1.951 Statutory provisions; amounts included in gross income of United States 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 Statutory provisions; Subpart F income defined.

1.952-1 Subpart F income defined.

1.952-2 Determination of gross income and taxable income of a foreign corporation.

1.953 Statutory provisions; income from insurance of United States risks. 1.953-1 Income from insurance of 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 Statutory provisions; foreign base company income.

1.954-1 Foreign base company income.

1.954-2 Foreign personal holding company income.

1.954-3 Foreign base company sales income.

1.954-4 Foreign base company services income.

1.954-5 Increase in qualified investments in less developed countries.

1.955 Statutory provisions; withdrawal of previously excluded Subpart F income from qualified investment.

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F income withdrawn from investment in less developed countries.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 corporation'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.

1.956 Statutory provisions; investment of earnings in United States property. 1.956-1 Shareholders pro rata share of a controlled foreign corporation's increase in earnings invested in United States property.

1.956-2 Definition of United States property.

1.957 Statutory provisions; controlled foreign corporations; United States per

sons.

1.957-1 Definition of controlled foreign corporation.

1.957-2 Controlled foreign corporation deriving income from insurance of United States risks.

1.957-3 Corporations organized in United States possessions.

1.957-4 United States person defined.

1.958 Statutory provisions; rules for determining stock ownership.

1.958-1 Direct and indirect ownership of stock.

1.959 Statutory provisions; exclusion from gross income of previously taxed earnings and profits.

1.959-1 Exclusion from gross income of 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 Statutory provisions; special rules for foreign tax credit.

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 second-tier corporation or by 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.

1.961 Statutory provisions; adjustments to basis of stock in controlled foreign corporations and of other property.

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 foreign corporations and of other property.

1.962 Statutory provisions; election by individuals to be subject to tax at corporate rates.

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 individuals.

1.962-3 Treatment of actual distributions.

1.962-4 Transitional rules for certain taxable years.

1.963 Statutory provisions; receipt of minimum distributions by domestic corporations.

1.963-1 Exclusion of Subpart F income upon receipt of minimum distribution. 1.963-2 Determination of the amount of the minimum distribution.

1.963-3 Distributions counting toward a minimum distribution.

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 Statutory provisions; miscellaneous provisions.

1.964-1 Determination of the earnings and profits of a foreign corporation.

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 Statutory provisions; reduction of Subpart F income of 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 Statutory provisions; definitions.

1.971-1 Definitions with respect to export trade corporations. 1.972 Statutory provisions; consolidation of group of export trade corporations. 1.972-1 Consolidation of group of export trade corporations.

1.981 Statutory provisions; election as to treatment of income subject to foreign community property laws.

1.981-1 Foreign law community income for taxable years beginning after December 31, 1966.

1.981-2 Foreign law community income for taxable years beginning before January 1, 1967.

1.981-3 Definitions and other special rules.

DOMESTIC INTERNATIONAL SALES CORPORATIONS

1.991 Statutory provisions; taxation of a domestic international sales corporation.

1.991-1 Taxation of a domestic international sales corporation.

1.992 Statutory provisions; requirements of a domestic international sales corporation.

1.992-3 Deficiency distributions to meet qualifications requirements.

1.992-4 Coordination with personal holding company provisions in case of certain produced film rents.

1.994 Statutory provisions; intercompany pricing rules.

1.994-1 Inter-company pricing rules for DISC's.

1.994-2 Marginal costing rules.

1.995 Statutory provisions; taxation of DISC income to shareholders.

1.995-1 Taxation of DISC income to shareholders.

1.995-2 Deemed distributions in qualified years.

1.995-3 Distributions upon disqualification.

1.995-4 Gain on certain dispositions of stock in a DISC.

1.995-5 Foreign investment attributable to producer's loans.

1.996 Statutory provisions; rules for allocation in the case of distributions and losses.

1.996-1 Rules for actual distributions and certain deemed distributions.

1.996-2 Ordering rules for losses.

1.996-3 Divisions of earnings and profits.

1.996-4 Subsequent effect of previous disposition of DISC stock.

1.996-5 Adjustment to basis.

1.996-6 Effectively connected income.

1.996-7 Carryover of DISC tax attributes.

1.996-8 Effect of carryback of capital loss or net operating loss to prior DISC taxable year.

1.997 Statutory provisions; special Subchapter C rules.

1.997-1 Special rules for Subchapter C of the Code.

GAIN OR LOSS ON DISPOSITION OF PROPERTY

DETERMINATION OF AMOUNT OF AND RECOGNITION OF GAIN OR LOSS

1.1001 Statutory provisions; determination of amount of and recognition of gain or loss.

1.1001-1 Computation of gain or loss.

1.1002 Statutory provisions; recognition of gain or loss.

1.1002-1 Sales or exchanges.

BASIS RULES OF GENERAL APPLICATION

1.1011 Statutory provisions; adjusted basis for determining gain or loss. 1.1011-1

Adjusted basis.

1.1011-2 Bargain sale to a charitable organization.

1.1012 Statutory provisions; basis of property-cost. 1.1012-1 Basis of property.

1.1012-2 Transfers in part a sale and in part a gift.

1.1013 Statutory provisions; basis of property included in inventory. 1.1013-1 Property included in inventory.

1.1014 Statutory provisions; basis of property acquired from a decedent. 1.1014-1 Basis of property acquired from a decedent.

1.1014-2 Property acquired from a decedent.

1.1014-3 Other basis rules.

1.1014-4 Uniformity of basis; adjustment to basis.

1.1014-5 Gain or loss.

1.1014-6 Special rule for adjustments to basis where property is acquired from a decedent prior to his death.

1.1014-7 Example applying rules of §§ 1.1014-4 through 1.1014-6 to case involving multiple interests.

1.1014-8 Bequest, devise, or inheritance of a remainder interest.

1.1014-9 Special rule with respect to DISC stock.

1.1015 Statutory provisions; basis of property acquired by gifts and transfers in trust.

1.1015-1 Basis of property acquired by gift after December 31, 1920.

1.1015-2 Transfer of property in trust after December 31, 1920.

1.1015-3 Gift or transfer in trust before January 1, 1921.

1.1015-4 Transfers in part a gift and in part a sale.

1.1015-5 Increased basis for gift tax paid.

1.1016 Statutory provisions; adjustments to basis.

1.1016-1 Adjustments to basis; scope of section.

1.1016-2 Items properly chargeable to capital account.

1.1016-3 Exhaustion, wear and tear, obsolescence, amortization, and depletion for periods since February 28, 1913.

1.1016-4 Exhaustion, wear and tear, obsolescence, amortization, and depletion; periods during which income was not subject to tax.

1.1016-5 Miscellaneous adjustments to basis.

1.1016-6 Other applicable rules.

1.1016-7 Adjusted basis; cancellation of indebtedness under Bankruptcy Act.

1.1016-8 Adjusted basis; cancellation of indebtedness; special cases.

1.1016-9 Adjusted basis; mutual savings banks, building and loan associations, and cooperative banks.

1.1016-10 Substituted basis.

1.1017 Statutory provisions; discharge of indebtedness.

1.1017-1 Adjusted basis; discharge of indebtedness; general rule.

1.1017-2 Adjusted basis; discharge of indebtedness; special cases.

1.1018 Statutory provisions; adjustment of capital structure before September 22, 1938.

1.1018-1 Adjusted basis; exception to section 270 of the Bankruptcy Act, as amended.

1.1019 Statutory provisions; property on which lessee has made improvements. 1.1019-1 Property on which lessee has made improvements.

1.1020 Statutory provisions; election in respect of depreciation, etc., allowed before 1952.

1.1020-1 Election as to amounts allowed in respect of depreciation, etc., before 1952.

1.1021 Statutory provisions; sale of annuities.

1.1021-1 Sale of annuities.

1.1022 Statutory provisions; cross references.

COMMON NONTAXABLE EXCHANGES

1.1031(a) Statutory provisions; exchange of property held for productive use or investment; nonrecognition of gain or loss from exchanges solely in kind.

1.1031(a)-1 Property held for productive use in trade or business or for investment.

1.1031(b) Statutory provisions; exchange of property held for productive use or investment; gain from exchanges not solely in kind.

1.1031(b)-1 Receipt of other property or money in tax-free exchange.

1.1031(c) Statutory provisions; exchange of property held for productive use or investment; loss from exchanges not solely in kind.

1.1031(c)-1 Nonrecognition of loss.

1.1031(d) Statutory provisions; exchange of property held for productive use or investment; basis.

1.1031(d)-1 Property acquired upon a tax-free exchange.

1.1031(d)-2 Treatment of assumption of liabilities.

1.1031(e) Statutory provisions; exchange of property held for productive use or investment; exchanges of livestock of different sexes.

1.1031(e)-1 Exchange of livestock of different sexes.

1.1032 Statutory provisions; exchange of stock for property.

1.1032-1 Disposition by a corporation of its own capital stock.

1.1033(a) Statutory provisions; involuntary conversions; general rule.

1.1033(a)-1 Involuntary conversions; nonrecognition of gain.

1.1033(a)-2 Involuntary conversion where disposition of the converted property occurred after December 31, 1950.

1.1033(a)-3 Involuntary conversion where disposition of the converted property occurred before January 1, 1951.

1.1033(a)-4 Replacement funds where disposition of the converted property occurred before January 1, 1951.

1.1033(b) Statutory provisions; involuntary conversions; residence of taxpayer. 1.1033(b)-1 Involuntary conversion of principal residence.

1.1033(c) Statutory provisions; involuntary conversions; basis of property acquired through involuntary conversion.

1.1033(c)-1 Basis of property acquired as a result of an involuntary conversion. 1.1033(d) Statutory provisions; involuntary conversions; property sold pursuant to reclamation laws.

1.1033(d)-1 Disposition of excess property within irrigation project deemed to be involuntary conversion.

1.1033(e) Statutory provisions; involuntary conversions; livestock destroyed by disease.

1.1033(e)-1 Destruction or disposition of livestock because of disease. 1.1033(f) Statutory provisions; livestock sold on account of drought. 1.1033(f)-1 Sale or exchange of livestock solely on account of drought.

1.1033(g) Statutory provisions; involuntary conversions; condemnation of real property held for productive use in trade or business or for investment. 1.1033(g)-1 Condemnation of real property held for productive use in trade or business or for investment.

1.1033(h) Statutory provisions; involuntary conversions; cross references. 1.1033(h)-1 Effective date.

1.1034 Statutory provisions; sale or exchange of residence.

1.1034-1 Sale or exchange of residence.

1.1035 Statutory provisions; certain exchanges of insurance policies.

1.1035-1 Certain exchanges of insurance policies.

1.1036 Statutory provisions; stock for stock of same corporation.

1.1036-1 Stock for stock of the same corporation.

1.1037 Statutory provisions; certain exchanges of United States obligations. 1.1037-1 Certain exchanges of United States obligations.

1.1038 Statutory provisions; certain reacquisitions of real property.

1.1038-1 Reacquisitions of real property in satisfaction of indebtedness. 1.1038-2 Reacquisition and resale of property used as a principal residence. 1.1038-3 Election to have section 1038 apply for taxable years beginning after December 31, 1957.

1.1039 Statutory provisions; certain sales of low-income housing projects.