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able accordance accrued acquired activities allocable allowed amount apply apportioned apportionment assets basis beginning capital capital gain carried Code computed conduct considered costs deduction deemed derived described determined Director disposition distribution dividends effectively effectively connected eign election engaged example excess exchange exemptions expenses facts fair market value filed foreign corporation foreign country gain graph gross income grouping held imposed income from sources income tax interest Internal less levy limitation loss meaning ment method mineral paid paragraph partnership payment percent percentage period person portion possession profits pursuant qualifying real estate real property interest reason receipts received regulations relating resident respect rules securities share shareholder solely Stat statement subdivision subparagraph taken taxable income taxes paid taxpayer term tion trade or business transactions treated trust U.S. real property United
71. lappuse - States, shall be treated as derived partly from sources within and partly from sources without the United States.
66. 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.
197. lappuse - In the case of an alien resident of the United States, the amount of any such taxes paid or accrued during the taxable year to any foreign country, if the foreign country of which such alien resident is a citizen or subject, in imposing such taxes, allows a similar credit to citizens of the United States residing in such country; and (4) PARTNERSHIPS AND ESTATES.
69. lappuse - The labor or services are performed by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year...
188. 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.
112. 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) Gains, profits, and income from the sale of real property located in the United States.
217. lappuse - For purposes of this subpart and of sections 164(a) and 275(a), the term "income, war profits, and excess profits taxes" shall include a tax paid in lieu of a tax on. income, war profits, or excess profits otherwise generally imposed by any foreign country or by any possession of the United States.
171. lappuse - ... (c) INCOME OF FOREIGN GOVERNMENTS AND OF INTERNATIONAL ORGANIZATIONS. The income of foreign governments or international organizations received from investments in the United States in stocks, bonds, or other domestic securities, owned by such foreign governments or...
286. lappuse - States (1) If 80 per centum or more of the gross income of such citizen or domestic corporation (computed without the benefit of this section) for the three-year period immediately preceding the close of the taxable year (or for such part of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States...
44. lappuse - If the determination of such amount depends in whole or in part on the income or profits derived by any person from such property (except that any amount so received or accrued shall not be excluded from the term "rents from real property...