CHAPTER I-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. Part 1 SUBCHAPTER A-INCOME TAX (continued) Income taxes (continued) Page 5 SUPPLEMENTARY PUBLICATIONS: Internal Revenue Service Looseleaf Regulations System. Additional supplementary publications are issued covering Alcohol and Tobacco Tax Regulations and Regulations Under Tax Conventions. SUBCHAPTER A-INCOME TAX (Continued) PART 1-INCOME TAXES Normal Taxes and Surtaxes (Continued) REGULATED INVESTMENT COMPANIES AND REAL ESTATE INVESTMENT TRUSTS Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules applicable to section 851(b)(4). 1.851-4 Determination of status. 1.851-5 Examples. 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 in come. 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. 1.852-12 Non-RIC earnings and profits. 1.853-1 Foreign tax credit allowed to share 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. 1.857-10 Information returns. 1.857-11 Non-REIT earnings and profits. 1.858-1 Dividends paid by a real estate investment trust after close of taxable year. 1.860-1 Deficiency dividends. 1.860-2 Requirements for deficiency dividends. 1.860-3 Interest and additions to tax. 1.860-4 Claim for credit or refund. 1.860-5 Effective date. 1.860A-0 Outline of REMIC provisions. 1.860A-1 Effective dates and transition rules. 1.860C-1 Taxation of holders of residual in terests. 1.860C-2 Determination of REMIC taxable income or net loss. 1.860D-1 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-2 Transfers to a REMIC. 1.860F-4 REMIC reporting requirements and other administrative rules. 1.860G-1 Definition of regular and residual Other rules. Treatment of foreign persons. interests. 1.860G-2 1.860G-3 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 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. 1.861-17 Allocation and apportionment of research and experimental expenditures. 1.861-18 Classification of transactions involving 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 income from certain sales of inventory. 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. 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). 1.865-1T Loss with respect to personal prop- NONRESIDENT ALIENS AND FOREIGN 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 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 indi viduals engaged in U.S. business or treated as having effectively connected in come. 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 in come 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 in come. 1.871-13 Taxation of individuals for taxable year of change of U.S. citizenship or residence. 1.881-0 Table of contents. 1.881-1 Manner of taxing foreign corporations. 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 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. 1.884-1 Branch profits tax. 1.884-2 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. 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 organizations. 1.894-1 Income affected by treaty. 1.894-1T Income affected by treaty (temporary). 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(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 |