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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1.–5. rezultāts no 28.
485. lappuse
... levy is an in- come tax is determined independently for each separate foreign levy . A for- eign levy is an income tax if and only if- ( i ) It is a tax ; and Except to the extent otherwise pro- vided in paragraphs ( a ) ( 3 ) ( ii ) ...
... levy is an in- come tax is determined independently for each separate foreign levy . A for- eign levy is an income tax if and only if- ( i ) It is a tax ; and Except to the extent otherwise pro- vided in paragraphs ( a ) ( 3 ) ( ii ) ...
486. lappuse
... levy ( and the amount paid pursuant to each such element ) must be separated . No credit is allowable for a payment pur- suant to a foreign levy by a dual capac- ity taxpayer ( as defined in paragraph ( a ) ( 2 ) ( ii ) ( A ) of this ...
... levy ( and the amount paid pursuant to each such element ) must be separated . No credit is allowable for a payment pur- suant to a foreign levy by a dual capac- ity taxpayer ( as defined in paragraph ( a ) ( 2 ) ( ii ) ( A ) of this ...
491. lappuse
... levy's base allows a deduction for the other levy is immaterial in reaching that de- termination . ( c ) Soak - up taxes .— ( 1 ) In general . Pur- suant to paragraph ( a ) ( 3 ) ( ii ) of this sec- tion , the predominant character of a ...
... levy's base allows a deduction for the other levy is immaterial in reaching that de- termination . ( c ) Soak - up taxes .— ( 1 ) In general . Pur- suant to paragraph ( a ) ( 3 ) ( ii ) of this sec- tion , the predominant character of a ...
492. lappuse
... levy or levies in a single or separate statutes . A levy imposed by one taxing authority ( e.g. , the national government of a foreign country ) is always separate for pur- poses of sections 901 and 903 from a levy imposed by another ...
... levy or levies in a single or separate statutes . A levy imposed by one taxing authority ( e.g. , the national government of a foreign country ) is always separate for pur- poses of sections 901 and 903 from a levy imposed by another ...
493. lappuse
... levy must be analyzed separately to determine whether it is an income tax within the meaning of paragraph ( a ) ( 1 ) ... levy that is the sum of two or more separately computed amounts , and each such amount is computed by reference to a ...
... levy must be analyzed separately to determine whether it is an income tax within the meaning of paragraph ( a ) ( 1 ) ... levy that is the sum of two or more separately computed amounts , and each such amount is computed by reference to a ...
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Bieži izmantoti vārdi un frāzes
adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation December 31 deduction described in paragraph determined distribution domestic corporation dual capacity taxpayers earnings and profits effectively connected election entity erty estate investment trust Example excess fair market value foreign cor foreign country foreign income taxes foreign mineral income foreign source graph gross income holder income from sources interest expense levy liability ment nonresident alien individual partnership passive income payment percent poration post-October pursuant qualified real estate investment real property holding real property interest received related person REMIC resident residual grouping respect share source income spect statutory grouping subdivision subparagraph tax treaty taxable income taxable years beginning taxes paid terest tion trade or business transaction treated U.S. assets U.S. real property U.S. shareholder U.S. tax unit investment trust United unused foreign tax X tax
Populāri fragmenti
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...