Taxable Years Beginning in 1945 Sec. 118. Loss from wash sales of stock or securities. Same as 1944. Taxable Years Beginning in 1944 Sec. 117. (k) (2) In the case of the disposal of timber (held for more than six months prior to such disposal) by the owner thereof under any form or type of contract by virtue of which the owner retains an economic interest in such timber, the difference between the amount received for such timber and the adjusted depletion basis thereof shall be considered though it were a gain or loss, as the case may be, upon the sale of such timber. Sec. 117 (k), I. R. C., supra, added to I. R. C. by Sec. 127 (a), R. A. of 1943. Retroactivity Sec. 101 of said Act makes said amendment inserting Sec. 117 (k) (1), I. R. C., applicable to taxable years beginning after Dec. 31, 1943; but Sec. 127 (c) of said Act provides that a provision having the effect of Sec. 117 (k) (2), I. R. C., inserted by said amendment, shall be deemed to be included in the revenue laws, respectively, applicable to taxable years beginning after Feb. 28, 1913. as Sec. 118. Loss from wash sales of stock or securities. Sec. 118. (a) In the case of any loss claimed to have been sustained from any sale or other disposition of shares of stock or securities where it appears that, within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange upon which the entire amount of gain or loss was recognized by law), or has entered into a contract or option so to acquire, substantially identical stock or securities, then no deduction for the loss shall be allowed under section 23 (e) (2); nor shall such deduction be allowed under section 23 (f) unless the claim is made by a corporation, a dealer in stocks or securities, and with respect to a transaction made in the ordinary course of its busi ness. Sec. 118. (b) If the amount of stock or securities acquired (or covered by the contract or option Taxable Years Beginning before 1944 Sec. 118. Loss from wash sales of stock or securities. Section originated 1921 as For any amendments prior to Second Edition, pp. 94, 196, Sec. 119. (a) (1) Interest.-Interest from the United States, any Territory, any political subdivision. of a Territory, or the District of Columbia, and interest on bonds, notes, or other interest-bearing obligations of residents, corporate or otherwise, not including (A) interest on deposits with persons carrying on the banking business paid to persons not engaged in business within the United States or (B) interest received from a resident alien individual, a resident foreign corporation, or a domestic corporation, when it is shown to the satisfaction of the Commissioner that less than 20 per centum of the gross income of such resident payor or domestic corporation has been derived from sources within the United States, as determined under the provisions of this sec Sec. 119. (a) Gross income from sources in United States. Sec. 119. (a) (1) Interest. Same as 1944. Sec, 119. (a) Gross income from sources in United States. Sec. 119. (a) (1) Interest. Same as 1944. Sec. 119. (a) (1) Interest. Same as 1944. Sec. 119. (a) Gross income from sources in United States.The following items of gross income shall be treated as income from sources within the United States: Sec. 119. (a) (1) Interest.—Interest from the United States, any Territory, any political subdivision of a Territory, or the District of Columbia, and interest on bonds, notes, or other interest-bearing obligations of residents, corporate or otherwise, not including (A) interest on deposits with persons carrying on the banking business paid to persons not engaged in business within the United States or (B) interest received from a resident alien individual, a resident foreign corporation, or a domestic corporation, when it is shown to the satisfaction of the Commissioner that less than 20 per centum of the gross income of such resident payor or domestic corporation has been derived from sources within the United States, as determined under the provisions of this sec Sec. 119. (a) Gross income from sources in United States. Taxable Years Beginning in 1949 tion, for the three-year period ending with the close of the taxable year of such payor preceding the payment of such interest, or for such part of such period as may be applicable, or (C) income derived by a foreign central bank of issue from bankers' acceptances; Sec. 119. (a) (2) Dividends.— The amount received as dividends (A) from a domestic corporation other than a corporation entitled to the benefits of section 251, and other than a corporation less than 20 per centum of whose gross income is shown to the satisfaction of the Commissioner to have been derived from sources within the United States, as determined under the provisions of this section, for the three-year period ending with the close of the taxable year of such corporation preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence), or (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 as determined under the provisions of this section; 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; but dividends from a foreign corporation shall, for the purposes of section 131 (relating to foreign tax credit), be treated as income from sources without the United States; Sec. 119. (a) (3) Personal services.-Compensation for labor or ices. personal services performed in the United States, but in the case of a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of ninety days Sec. 119. (a) (3) Personal services. Same as 1944. Taxable Years Beginning in 1945 Sec. 119. (a) (2) Dividends. Same as 1944. Sec. 119. (a) (3) Personal services. Same as 1944. Taxable Years Beginning in 1944 tion, for the three-year period ending with the close of the taxable year of such payor preceding the payment of such interest, or for such part of such period as may be applicable, or (C) income derived by a foreign central bank of issue from bankers' acceptances; Sec. 119. (a) (2) Dividends.— The amount received as dividends (A) from a domestic corporation other than a corporation entitled to the benefits of section 251, and other than a corporation less than 20 per centum of whose gross income is shown to the satisfaction of the Commissioner to have been derived from sources within the United States, as determined under the provisions of this section, for the three-year period ending with the close of the taxable year of such corporation preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence), or (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 as determined under the provisions of this section; 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; but dividends from a foreign corporation shall, for the purposes of section 131 (relating to foreign tax credit), be treated as income from sources without the United States; Sec. 119. (a) (3) Personal services.-Compensation for labor or personal services performed in the United States, but in the case of a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of ninety days Taxable Years Beginning before 1944 Sec. 119. (a) (2) Dividends. Section originated 1921 as Second Edition, p. 122, Sec. 119. (a) (3) Personal services. Section originated 1921 as Second Edition, p. 122, |