Removal of Tax Barriers to Foreign Investment in the United States: Hearings, Eighty-ninth Congress, First Session, Along with Written Comments Submitted to the Committee on Ways and Means on H.R. 5916, to Remove Tax Barriers to Foreign Investment in the United States, June 30 and July 1, 1965U.S. Government Printing Office, 1965 - 161 lappuses |
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abroad American applicable Bache & Co balance of payments balance-of-payments barriers to foreign bill bonds BYRNES Chairman code section committee CONGRESS THE LIBRARY dealer deposits dividends received deduction effect eliminated engaged in business engaged in trade estates of nonresident exemption expatriate financing foreign banks foreign branch foreign country Fowler task force funds gift tax gross estate interest equalization tax Internal Revenue Code investment in U.S. investors issue June 24 legislation LIBRARY OF CONGRESS marital deduction ment million nonbusiness income nonresident alien decedents nonresident alien individual percent present law proposed amendment proposed Section provisions real property recommendations remove tax barriers resident alien resident foreign corporation Secretary FOWLER section 871 shares tax treaties tax treatment taxation tion trade or business Treasury U.S. agent U.S. banks U.S. citizens U.S. corporate securities U.S. dollars U.S. estate tax U.S. securities U.S. source income U.S. tax United WILBUR D withholding tax York Stock Exchange
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110. lappuse - United States. The following Items of gross income shall be treated as income from sources within the United States: (1) Interest.
2. lappuse - ... (B) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the three-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States...
106. lappuse - States, having the control, receipt,. custody, disposal, or payment of interest (except interest on deposits with persons carrying on the banking business paid to persons not engaged in business in the United States and not having an office or place of business therein...
11. lappuse - For purposes of this section, the term "charitable contribution" means a contribution or gift to or for the use of — (1) A State, a Territory, a possession of the United States, or any political subdivision of any of the foregoing, or the United States or the District of Columbia, but only if the contribution or gift is made for exclusively public purposes.
6. lappuse - This paragraph shall not apply to a disposition to an organization (other than a cooperative described in section 521) which is exempt from the tax imposed by this chapter.
4. 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; and the proper apportionment and allocation of the deductions with respect to sources of income within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary.
2. lappuse - ... engaged in trade or business within the United States, from sources within the United States, as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income...
2. lappuse - States as determined under the provisions of this part; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to its gross income from all sources...
3. lappuse - An election under this paragraph for any taxable year shall remain In effect for all subsequent taxable years, except that It may be revoked with the consent of the Secretary or his delegate with respect to any taxable year.
1. lappuse - Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.