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 investment companies.

1.852-3 Investment company taxable in

come.

1.852-4 Method of taxation of shareholders of regulated investment companies. 1.852-5 Earnings and profits of a regulated investment company.

1.852-6 Records to be kept for purpose of determining whether a corporation claiming to be a regulated investment company 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 applicable to designation under section 852(b)(3)(D).

1.852-10 Distributions in redemption of interests in unit investment trusts. 1.852-11 Treatment of certain losses attributable 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

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 investment trust after close of taxable year.

1.860-1 Deficiency dividends.

1.860-2 Requirements for deficiency dividends.

1.860-3 Interest and additions to tax. 1.860-4 Claim for credit or refund. 1.860-5 Effective date.

1.860A-0 Outline of REMIC provisions. 1.860A-1 Effective dates and transition rules.

1.860C-1 Taxation of holders of residual in

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 interests 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.

1.860G-1 Definition of regular and residual

Other rules.

Treatment of foreign persons.

interests.

1.860G-2 1.860G-3

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 regulations).

1.861-10 Special allocations of interest expense.

1.861-10T Special allocations of interest expense (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 adjustments for certain assets (temporary regulations).

1.861-13T Transition rules for interest expenses (temporary regulations). 1.861-14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary regulations).

1.861-15 Income from certain aircraft or vessels 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 research and experimental expenditures. 1.861-18 Classification of transactions involving 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 income from certain sales of inventory. 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.

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 effectively connected with U.S. business of nonresident aliens or foreign corporations.

1.864-4 U.S. source income effectively connected with U.S. business.

1.864-5 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 factoring 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 determine status of alien employees. 1.871-7 Taxation of nonresident alien individuals 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 trainees 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 patents, 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.

1.881-0 Table of contents.

1.881-1 Manner of taxing foreign corporations.

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 engaged 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 corporation.

1.882-4 Allowance of deductions and credits to foreign corporations. 1.882-5 Determination of interest deduction. 1.883-1 Exclusions from gross income of foreign corporations.

1.884-0 Overview of regulation provisions for section 884.

1.884-1 Branch profits tax.

1.884-2 Special rules for termination or incorporation 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 incorporation 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 (temporary). [Reserved]

1.884-4

Branch-level interest tax. 1.884-5 Qualified resident.

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 (temporary regulations).

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 organizations (temporary regulations).

1.892-7T Relationship to other Internal Revenue Code sections (temporary regulations).

1.893-1 Compensation of employees of foreign governments or international organizations.

1.894-1 Income affected by treaty. 1.894-1T Income affected by treaty (temporary).

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 deposits.

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 (temporary).

1.897-6T Nonrecognition exchanges applicable to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganizations (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 holding 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