The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1994 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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able activities adjusted allocated allowed amount apply apportioned apportionment assets attributable base basis branch Code computed conduct considered controlled debt deduction deemed defined derived described determined disposition distribution dividend domestic corporation earnings and profits effectively connected eign election engaged entity Example excess exchange expense facts fair market value filed foreign corporation foreign country foreign tax gain graph gross income held holder holding imposed income tax inter interest interest expense levy liability limitation loss meaning ment method paid paragraph partnership payment percent period person poration portion pursuant qualified real estate real property interest reason received reduced regulations REMIC resident respect rules securities separate share shareholder sources specific Stat statement taxable income taxpayer term tion trade or business transaction treated trust U.S. real property United
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297. lappuse - Rentals or royalties from property located In the United States or from any Interest In such property, Including rentals or royalties for the use of or for the privilege of using In the United States, patents, copyrights, secret processes and formulas, good will, trademarks, trade brands, franchises, and other like property; and (5) Sale of real property.
123. 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.
337. 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...
274. 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...
54. lappuse - Government securities, securities of other investment companies, and other securities for the purposes of this calculation limited in respect of any one issuer to an amount not greater in value than 5...
343. lappuse - For purposes of this section, the term "earned income" means wages, salaries, or professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered. In the case...
418. lappuse - The income of foreign governments received from investments in the United States in stocks, bonds, or other domestic securities, owned by such foreign governments, or from interest on deposits in banks in the United States of moneys belonging to such foreign governments, or from any other source within the United States...
271. lappuse - States or from the purchase of personal property without and its sale within the United States, shall be treated as derived entirely from sources within the country in which sold, except that gains, profits and income derived from the purchase of personal property within the United States and its sale within a possession of the United States...
446. 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.
424. lappuse - The Secretary of State shall certify to the Secretary of the Treasury the names of the foreign countries which grant an equivalent exemption to the employees of the Government of the United States performing...