 | United States. Tax Court - 2001 - 380 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends— (A) the sum of— (i) his pro rata share (determined under paragraph (2)) of... | |
 | Joseph Isenbergh - 2006 - 966 lapas
...such corporation is a controlled foreign corporation" is required to include various amounts in income "for his taxable year in which or with which such taxable year of the corporation ends." Inclusion in the income of a US shareholder thus arises in the US shareholder's... | |
 | 1967 - 548 lapas
...person who sold or exchanged the stock) was a qualified shareholder (as defined in section 1247 (c)) for his taxable year in which or with which such taxable year of the company ends, then the ratable share in respect of the share (or block) for such taxable year of... | |
 | 1971 - 782 lapas
...(i) The amount required, under section 1373 (b), to be included in the gross income of such person for his taxable year in which or with which such taxable year of the corporation ends, over (ii) The sum of all prior distributions of money made to such person after... | |
 | 1966 - 516 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends — (A) The sum of — (i) Except as provided in section 963, his pro rata share... | |
 | 1968 - 728 lapas
...person who sold or exchanged the stock) was a qualified shareholder (as defined in section 1247(c)) for his taxable year in which or with which such taxable year of the company ends, then the ratable share in respect of the share (or block) for such taxable year of... | |
 | 1971 - 552 lapas
...controlled foreign corporation must include his pro rata share of such subpart F income in his gross income for his taxable year in which or with which such taxable year of the foreign corporation ends. See section 952 (a). However, see paragraph (a) of § 1.957-2 for special... | |
 | 1969 - 556 lapas
...year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends — (A) The sum of — (1 ) Except as provided in section 963, his pro rata share... | |
 | 1972 - 868 lapas
...person who sold or exchanged the stock) was a qualified shareholder (as defined in section 1247(c» for his taxable year in which or with which such taxable year of the company ends, then the ratable share in respect of the share (or block) for such taxable year of... | |
 | 1968 - 544 lapas
...controlled foreign corporation must include his pro rata share of such subpart F income in his gross income for his taxable year in which or with which such taxable year of the foreign corporation ends. See section 952 (a). However, see paragraph (a) of § 1.957-2 for special... | |
| |
States shareholder (as defined in subsection (b)) of such corporation and who owns (within the meaning of section 958(a)) stock in such corporation on the last day, in such year, on which such corporation is a controlled foreign corporation shall include... 
