 | United States - 1964 - 1098 lapas
...year, on which such corporation is a controlled foreign corporation shall Include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends — (A) the sum of — (1) except as provided in section 963, his pro rata share... | |
 | 1978 - 948 lapas
...foreign corporations and of other property. (a) Increase in basis— (I) In general Except as provided in subparagraph (2) of this paragraph, the basis of...increase in case of election under section 962. In the cas of a United States shareholder wh- makes the election under section 962 for the taxable year, the... | |
 | 1978 - 952 lapas
...or such property in such shareholder's gross Income under section 95 К a) for his taxable year 1л which or with which such taxable year of such corporation...increase in case of election under section 962. In the cas of a United States shareholder wlu makes the election under section 962 for the taxable year, the... | |
 | 1970 - 868 lapas
...with rjspect to such stock or such property In such shareholder's gross Income under section 951 (a) for his taxable year in which or with which such taxable...required to be Included in gross Income under section 951 (a) was so Included In gross Income. (2) Limitation on amount of increase in case of election under... | |
 | 1996 - 764 lapas
...controlled foreign corporation must include his pro rata share of such subpart F income in his gross income for his taxable year in which or with which such taxable year of the foreign corporation ends. See section 952(a). However, see paragraph (a) of §1.957-2 for special... | |
 | 1978 - 1400 lapas
...of— (i) The amount required, under section 1373(b), to be included in the gross income of such person for his taxable year in which or with which such taxable year of the corporation ends, over (ii) The sum of all prior distributions of money made to such person after... | |
 | United States. Internal Revenue Service - 1968 - 1034 lapas
...(i) The amount required, under section 1373 (b), to be included in the gross income of such person for his taxable year in which or with which such taxable year of the corporation ends, over (ii) The sum of all prior distributions of money made to such person after... | |
 | United States. Congress. House. Committee on Ways and Means - 1967 - 1468 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation *■ ends — 1* "(A) his pro rata share (determined under 15 paragraph (2) ) of the... | |
 | United States. Internal Revenue Service - 1972 - 624 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends, his pro rata share (determined under section 956 (a) (2) of the Code) of the... | |
 | United States. Internal Revenue Service - 1976 - 624 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends, his pro rata share (determined under section 956 (a) (2) ) of the corporation's... | |
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States shareholder (as defined in subsection (b)) of such corporation and who owns (within the meaning of section 958(a)) stock in such corporation on the last day, in such year, on which such corporation is a controlled foreign corporation shall include... 
