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CHAPTER INTERNAL REVENUE SERVICE,
DEPARTMENT OF THE TREASURY

(CONTINUED)

EDITORIAL NOTE: IRS published a document at 45 FR 6088, Jan. 25, 1980, deleting statutory sections from their regulations. In chapter I cross references to the deleted material have been changed to the corresponding sections of the IRS Code of 1954 or to the appropriate regulations sections. When either such change produced a redundancy, the cross reference has been deleted. For further explanation, see 45 FR 20795, March 31, 1980.

SUBCHAPTER A-INCOME TAX (continued)

Part 1

Income taxes (continued)

Page

5

SUPPLEMENTARY PUBLICATIONS: Internal Revenue Service Looseleaf Regulations System.

Additional supplementary publications are issued covering Alcohol and Tobacco Tar Regulations and Regulations Under Tax Conventions.

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

DETERMINATION OF SOURCES OF INCOME 1.861-1 Income from sources within the

United States. 1.861-2 Interest. 1.861-3 Dividends. 1.861-4 Compensation for labor or personal

services. 1.861-5 Rentals and royalties. 1.861–6 Sale of real property. 1.861–7 Sale of personal property. 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 regula

tions). 1.861-10 Special allocations of interest ex

pense. 1.861-10T Special allocations of interest ex

pense (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 adjust

ments for certain assets (temporary reg

ulations). 1.861-13T Transition rules for interest ex

penses (temporary regulations). 1.861–14T Special rules for allocating and

apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary regula

tions). 1.861-15 Income from certain aircraft or ves

sels first leased on or before December 28,

1980. 1.861-16 Income from certain craft first

leased after December 28, 1980. 1.861-17 Allocation and apportionment of re

search and experimental expenditures. 1.861-18 Classification of transactions in

volving computer programs. 1.862–1 Income specifically from sources

without the United States. 1.863-0 Table of contents. 1.863-1 Allocation of gross income under

section 863(a). 1.863-2 Allocation and apportionment of

taxable income. 1.863.3 Allocation and apportionment of in

come from certain sales of inventory.

1.863-3AT Income from the sale of personal

property derived partly from within and partly from without the United States

(temporary regulations). 1.863-4Certain transportation services. 1.863-6 Income from sources within a for

eign 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 effec

tively connected with U.S. business of nonresident aliens or foreign corpora

tions. 1.864-4 U.S. source income effectively con

nected with U.S. business. 1.8645 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 fac

toring income (temporary). 1.865-1T Loss with respect to personal prop

erty other than stock (temporary). 1.865-2 Loss with respect to stock. 1.865-2T Loss with respect to stock (tem

porary).

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 indi

viduals. 1.871-3 Residence of alien seamen. 1.871-4 Proof of residence of aliens. 1.871-5 Loss of residence by an alien. 1.871-6 Duty of withholding agent to deter

mine status of alien employees. 1.871–7 Taxation of nonresident alien indi

viduals not engaged in U.S. business. 1.871-8 Taxation of nonresident alien indi

viduals engaged in U.S. business or treated as having effectively connected in

come. 1.871-9 Nonresident alien students or train

ees deemed to be engaged in U.S. busi

ness. 1.871-10 Election to treat real property in

come as effectively connected with U.S.

business. 1.871-11 Gains from sale or exchange of pat

ents, copyrights, or similar property. 1.871–12 Determination of tax on treaty in

come. 1.871-13 Taxation of individuals for taxable

year of change of U.S. citizenship or residence.

REGULATIONS APPLICABLE TO TAXABLE YEARS

PRIOR TO DECEMBER 30, 1996 1.863-3A Income from the sale of personal

property derived partly from within and partly from without the United States.

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1.8810 Table of contents. 1.881-1 Manner of taxing foreign corpora

tions. 1.881-2 Taxation of foreign corporations not

engaged in U.S. business. 1.881–3 Conduit financing arrangements. 1.881-4 Recordkeeping requirements con

cerning conduit financing arrangements. 1.882-0 Table of contents. 1.882–1 Taxation of foreign corporations en

gaged 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 corpora

tion. 1.8824 Allowance of deductions and credits

to foreign corporations. 1.882–5 Determination of interest deduction. 1.883–1 Exclusions from gross income of for

eign corporations. 1.8840 Overview of regulation provisions for

section 884. 1.884-1 Branch profits tax. 1.884-2 Special rules for termination or in

corporation of a U.S. trade or business or liquidation or reorganization of a foreign

corporation or its domestic subsidiary. 1.884–2T Special rules for termination or in

corporation 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 (tem

porary). (Reserved] 1.8844 Branch-level interest tax. 1.884-5 Qualified resident.

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 organiza

tions (temporary regulations). 1.892–7T Relationship to other Internal Rev

enue Code sections (temporary regula

tions). 1.893-1 Compensation of employees of for

eign governments or international orga

nizations. 1.894–1 Income affected by treaty. 1.894–1T Income affected by treaty (tem

porary). 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 depos

its. 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 (tem

porary). 1.897-6T Nonrecognition exchanges applica

ble to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganiza

tions (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 hold

ing corporation as a condition for electing section 897(i) 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

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 (tem

porary regulations).

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. 1.902–0 Outline of regulations provisions for

section 902.

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