Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1969 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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adjusted basis apply base company sales carryback class of stock company sales income computed controlled foreign corporation December 31 deductions derived from sources determined distribution domestic corporation earnings and profits election estate investment trust excess limitation excess profits taxes exemption foreign base company foreign country graph gross income income derived income from sources income tax invested in United investments in less less developed countries located ment nonresident alien individual paid or accrued paragraph percent period poration Puerto Rico purposes of section qualified investments rata share real estate investment real property regulated investment company regulations thereunder reinsuring related person respect sale or exchange section 954 Statutory provisions stocks or securities subdivision subparagraph subpart F income subsection taken into account taxable income taxpayer tion trade or business trolled foreign corporation United States person United States property United States risks United States shareholder unused foreign tax Virgin Islands war profits
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77. 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...
219. lappuse - If an exchange would be within the provisions of subsection (b) (1) to (5), inclusive, of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain or loss, but also of other property or money, then no loss from the exchange shall be recognized.
25. lappuse - States by such corporation. (4) Rentals and royalties. 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.
47. lappuse - A domestic corporation may claim a credit for (i) the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country, or to any possession of the United States; and (ii) the taxes deemed to have been paid or accrued under section 902, 905(b), or 960.
72. lappuse - Indies, and which satisfies the following conditions : (1) if 95 percent or more of the gross income of such domestic corporation for the 3-year period immediately preceding the close of the taxable year (or for such part of such period during which the corporation was in existence) was derived from sources...
219. lappuse - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
47. lappuse - For the purposes of this title, the term "international organization " means a public international organization in which the United States participates pursuant to any treaty or under the authority of any Act of Congress authorizing such participation or making an appropriation for such participation, and which shall have been designated by the President through appropriate Executive order as being entitled to enjoy the privileges, exemptions, and immunities herein provided.
244. lappuse - ... (2) If a distribution made in pursuance of a plan of reorganization is within the provisions of paragraph (1) of this subsection but has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph...
244. lappuse - ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.
219. lappuse - ... held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, choses in action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.