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

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 company.

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 Distributions in redemption of interests in unit investment trusts. 1.852-11 Treatment of certain losses attributable to periods after October 31 of a taxable year.

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

REAL ESTATE INVESTMENT TRUSTS

1.856-0 Revenue Act of 1978 amendments not included.

1.856-1 Definition of real estate investment trust.

1.856-7 Certain corporations, etc., that are considered to meet the gross income requirements.

1.857-2 Real estate investment trust taxable income and net capital gain.

1.857-3 Net income from foreclosure property.

1.857-4 Tax imposed by reason of the failure to meet certain source-of-income requirements.

1.857-5 Net income and loss from prohibited transactions.

1.857-6 Method of taxation of shareholders of real estate investment trusts.

1.857-7 Earnings and profits of a real estate investment trust.

1.857-8 Records to be kept by a real estate investment trust.

1.857-9 Information required in returns of shareholders.

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

1.860C-2

1.860D-1

Determination of REMIC taxable income or net loss.
Definition of a REMIC.

1.860E-1 Treatment of taxable income of a residual interest holder in excess of daily accruals.

1.860E-2 Tax on transfers of residual interests to certain organizations. 1.860F-1 Qualified liquidations.

1.860F-4 REMIC reporting requirements and other administrative rules.

1.860G-1 Definition of regular and residual interests.

1.860G-2 Other rules.

1.860G-3 Treatment of foreign persons.

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

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

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

1.861-9T Allocation and apportionment of interest expense (temporary regulations).

1.861-10 Special allocations of interest expense.

1.861-10T Special allocations of interest expense (temporary regulations).

1.861-11T Special rules for allocating and apportioning interest expense of an affiliated group of corporations (temporary regulations).

1.861-12T Characterization rules and adjustments for certain assets (temporary

regulations).

1.861-13T Transition rules for interest expenses (temporary regulations).

1.861-14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary regulations).

1.861-15

Income from certain aircraft or vessels first leased on or before December 28, 1980.

1.861-16 Income from certain craft first leased after December 28, 1980.

1.862-1 Income specifically from sources without the United States.

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.

1.863-3T Income from the sale of personal property derived partly from within and partly from without the United States (temporary regulations).

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.

1.863-7 Allocation of income attributable to certain notional principal contracts under section 863(a).

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.

1.864-8T Treatment of related person factoring income (temporary).

NONRESIDENT ALIENS AND FOREIGN CORPORATIONS

NONRESIDENT ALIEN INDIVIDUALS

1.871-1 Classification and manner of taxing alien individuals.

1.871-2 Determining residence of alien individuals.

1.871-6 Duty of withholding agent to determine status of alien employees. 1.871-7 Taxation of 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. busi

ness.

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.

1.872-1

Gross income of nonresident alien individuals.

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

1.873-1

Deductions allowed nonresident alien individuals.

1.874-1 Allowance of deductions and credits to nonresident alien individuals. 1.875-1 Partnerships.

FOREIGN CORPORATIONS

1.881-1 Manner of taxing foreign corporations.

1.881-2 Taxation of foreign corporations not engaged in U.S. 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 and credits to foreign corporations.

1.882-5 Determination of interest deduction.

1.883-1 Exclusions from gross income of foreign corporations.

1.884-0 Overview of regulation provisions for section 884.

1.884-2T Special rules for termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary (temporary).

1.884-3T Coordination of branch profits tax with second-tier withholding (temporary). [Reserved]

1.884 4 Branch-level interest tax.

1.884-5 Qualified resident.

MISCELLANEOUS PROVISIONS

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

1.892-1T Purpose and scope of regulations (temporary regulations).

1.892-2T Foreign government defined (temporary regulations). 1.892-3T Income of foreign governments (temporary regulations).

1.892-4T Commercial activities (temporary regulations).

1.892-5T Controlled commercial entity (temporary regulations).

1.892-6T Income of international organizations (temporary regulations).

1.892-7T Relationship to other Internal Revenue Code sections (temporary regulations).

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

nizations.

1.894-1 Income affected by treaty.

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.

1.897-1 Taxation of foreign investment in United States real property interests, definition of terms.

1.897-2 United States real property holding corporations.

1.897-3 Election by foreign corporation to be treated as a domestic corporation under section 897(i).

1.897-4AT Table of contents (temporary).

1.897-5T Corporate distributions (temporary).

1.897-6T Nonrecognition exchanges applicable to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganizations (temporary).

1.897-7T Treatment of certain partnership interests as entirely U.S. real property interests under sections 897(g) and 1445(e) (temporary).

1.897-8T Status as a U.S. real property holding corporation as a condition for electing section 897(1) pursuant to §1.897-3 (temporary).

1.897-9T Treatment of certain interest in publicly traded corporations, definition of foreign person, and foreign governments and international organizations (temporary).

INCOME FROM SOURCES WITHOUT THE UNITED STATES

FOREIGN TAX CREDIT

1.901-1

Allowance of credit for taxes.

1.901-2 Income, war profits, or excess profits tax paid or accrued.

1.901-2A Dual capacity taxpayers.

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

1.902-1 Credit for domestic corporate shareholder of a foreign corporation. 1.902-2 Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation.

1.903-1

Taxes in lieu of income taxes.

1.904-0 Outline of regulation provisions for section 904. 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 application of section 904 with respect to certain categories of

income.

1.904-5 Look-through rules as applied to controlled foreign corporations and other entities.

1.904-6 Allocation and apportionment of taxes.

1.904(b)-1 Treatment of capital gains for corporations.

1.904(b)-2 Treatment of capital gains for other taxpayers.

1.904(b)-3 Sale of personal property.

1.904(b) 4 Effective date.

1.904(f)-1 Overall foreign loss and the overall foreign loss account.

1.904(f)-2 Recapture of overall foreign losses.

1.904(f)-3 Allocation of net operating losses and net capital losses.

1.904(f) 4 Recapture of foreign losses out of accumulation distributions from a foreign trust.

1.904(f)-5 Special rules for recapture of overall foreign losses of a domestic trust. 1.904(f)-6 Transitional rule for recapture of FORI and general limitation overall foreign losses incurred in taxable years beginning before January 1, 1983, from foreign source taxable income subject to general limitation in taxable years beginning after December 31, 1982.

1.904(f)-7-1.904(f)-11 [Reserved]

1.904(f)-12 Transition rules.

1.905-1 When credit for taxes may be taken.

1.905-2 Conditions of allowance of credit.

1.905-3T Adjustments to the pools of foreign taxes and earnings and profits when the allowable foreign tax credit changes (temporary).

1.905-4T Notification and redetermination of United States tax liability (temporary).

1.905-5T Foreign tax redeterminations and currency translation rules for foreign tax redeterminations occurring in taxable years beginning prior to January 1, 1987 (temporary).

REGULATIONS APPLICABLE TO TAXABLE YEARS BEGINNING AFTER DECEMBER 31, 1982 1.907-0 Outline of regulation provisions for section 907.

1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).

1.907(b)-1 Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982).

1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).