CHAPTER INTERNAL REVENUE SERVICE, (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. SUBCHAPTER A-INCOME TAX (continued) Part 1 Income taxes (continued) Page 5 SUPPLEMENTARY PUBLICATIONS: Internal Revenue Service Looseleaf Regulations System. Additional supplementary publications are issued covering Alcohol and Tobacco Tar Regulations and Regulations Under Tax Conventions. 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 in vestment companies. 1.852–3 Investment company taxable in come. 1.8524 Method of taxation of shareholders of regulated investment companies. 1.852–5 Earnings and profits of a regulated investment company. 1.8526 Records to be kept for purpose of de termining whether a corporation claiming to be a regulated investment com pany 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 ap plicable to designation under section 852(b)(3)(D). 1.852-10 Distributions in redemption of in terests in unit investment trusts. 1.852-11 Treatment of certain losses attrib utable 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 holders. 1.853-2 Effect of election. 1.853-3 Notice to shareholders. 1.8534 Manner of making election. 1.854-1 Limitations applicable to dividends received from regulated investment com pany. 1.854-2 Notice to shareholders. 1.8543 Definitions. 1.855–1 Dividends paid by regulated invest ment company after close of taxable year. REAL ESTATE INVESTMENT TRUSTS 1.856-0 Revenue Act of 1978 amendments not TAX BASED ON INCOME FROM SOURCES WITHIN OR WITHOUT THE UNITED STATES 1.856-1 Definition of real estate investment trust. 1.856-2 Limitations. 1.8563 Defi ons. 1.856-4 Rents from real property. 1.856-5 Interest. 1.856-6 Foreclosure property. 1.856–7 Certain corporations, etc., that are considered to meet the gross income re quirements. 1.856-8 Revocation or termination of elec tion. 1.857-1 Taxation of real estate investment trusts. 1.857-2 Real estate investment trust taxable income and net capital gain. 1.857-3 Net income from foreclosure prop erty. 1.857-4 Tax imposed by reason of the failure to meet certain source-of-income re quirements. 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 in vestment trust after close of taxable year. dends. and transition 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 inter ests 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. interests. included. DETERMINATION OF SOURCES OF INCOME 1.861-1 Income from sources within the United States. 1.861-2 Interest. 1.861-3 Dividends. 1.861-4 Compensation for labor or personal services. 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 regula tions). 1.861-10 Special allocations of interest ex pense. 1.861-10T Special allocations of interest ex pense (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 adjust ments for certain assets (temporary reg ulations). 1.861-13T Transition rules for interest ex penses (temporary regulations). 1.861–14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary regula tions). 1.861-15 Income from certain aircraft or ves sels 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 re search and experimental expenditures. 1.861-18 Classification of transactions in volving 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 in come from certain sales of inventory. 1.863-3AT Income from the sale of personal property derived partly from within and partly from without the United States (temporary regulations). 1.863-4Certain transportation services. 1.863-6 Income from sources within a for eign country or possession of the United States. 1.863-7 Allocation of income attributable to certain notional principal contracts 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 effec tively connected with U.S. business of nonresident aliens or foreign corpora tions. 1.864-4 U.S. source income effectively con nected with U.S. business. 1.8645 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 fac toring income (temporary). 1.865-1T Loss with respect to personal prop erty other than stock (temporary). 1.865-2 Loss with respect to stock. 1.865-2T Loss with respect to stock (tem porary). NONRESIDENT ALIENS AND FOREIGN CORPORATIONS 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 deter mine status of alien employees. 1.871–7 Taxation of nonresident alien indi viduals 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 train ees 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 pat ents, 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. 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. 1.8810 Table of contents. 1.881-1 Manner of taxing foreign corpora tions. 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 en gaged 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 corpora tion. 1.8824 Allowance of deductions and credits to foreign corporations. 1.882–5 Determination of interest deduction. 1.883–1 Exclusions from gross income of for eign corporations. 1.8840 Overview of regulation provisions for section 884. 1.884-1 Branch profits tax. 1.884-2 Special rules for termination or in corporation 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 in corporation 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 (tem porary). (Reserved] 1.8844 Branch-level interest tax. 1.884-5 Qualified resident. 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 organiza tions (temporary regulations). 1.892–7T Relationship to other Internal Rev enue Code sections (temporary regula tions). 1.893-1 Compensation of employees of for eign governments or international orga nizations. 1.894–1 Income affected by treaty. 1.894–1T Income affected by treaty (tem porary). 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 depos its. 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 (tem porary). 1.897-6T Nonrecognition exchanges applica ble to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganiza tions (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 hold ing 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 STATES FOREIGN TAX CREDIT 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 (tem porary regulations). 1.901–1 Allowance of credit for taxes. 1.901–2 Income, war profits, or excess profits tax paid or accrued. 1.901–2A Dual capacity taxpayers. 1.901–3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit. 1.902–0 Outline of regulations provisions for section 902. |
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