The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1970 - Administrative law The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Page 7
... distributions by domestic corpo- rations . 1.963-1 Exclusion of subpart F income upon receipt of minimum distribution . 1.963-2 Determination of the amount of the minimum distribution . 1.963-3 Distributions counting toward a minimum ...
... distributions by domestic corpo- rations . 1.963-1 Exclusion of subpart F income upon receipt of minimum distribution . 1.963-2 Determination of the amount of the minimum distribution . 1.963-3 Distributions counting toward a minimum ...
Page 11
... distribution under section 1081 ( c ) ( 1 ) or ( 2 ) . 1.1082-6 Basis of property acquired under section 1081 ( d ) in transactions between corporations of the same system group . 1.1083 Statutory provisions ; exchanges and distributions ...
... distribution under section 1081 ( c ) ( 1 ) or ( 2 ) . 1.1082-6 Basis of property acquired under section 1081 ( d ) in transactions between corporations of the same system group . 1.1083 Statutory provisions ; exchanges and distributions ...
Page 24
... distribution from such earn- ings and profits . If distributions had been made in the taxable year in the amount of the earnings and profits then available for distribution , $ 500,000 , the corporation would have as of the be- ginning ...
... distribution from such earn- ings and profits . If distributions had been made in the taxable year in the amount of the earnings and profits then available for distribution , $ 500,000 , the corporation would have as of the be- ginning ...
Page 27
... distribution shall not be considered as a dividend unless such 36-054-70- -3 distribution is pro - rata , with no prefer- ence to any share of stock as compared with other shares of the same class ex- cept to the extent that the former ...
... distribution shall not be considered as a dividend unless such 36-054-70- -3 distribution is pro - rata , with no prefer- ence to any share of stock as compared with other shares of the same class ex- cept to the extent that the former ...
Page 33
... distribution is made . ( d ) Foreign tax election . If an invest- ment company to which section 858 is ap- 8 plicable for the taxable year makes distribution as provided in subsection ( a ) of this section , the shareholders shall con ...
... distribution is made . ( d ) Foreign tax election . If an invest- ment company to which section 858 is ap- 8 plicable for the taxable year makes distribution as provided in subsection ( a ) of this section , the shareholders shall con ...
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Common terms and phrases
adjusted basis allocated amount apply capital gain chain or group class of stock computed controlled foreign corporation Corporation's December 31 deductions deemed paid derived from sources described in section determined dividends domestic corporation earnings and profits election erty estate investment trust export trade assets fair market value foreign base company foreign country foreign income tax foreign tax credit gain or loss graph gross income holding company income derived income from sources investments in less less developed country liability ment minimum distribution nonresident alien paid or accrued paragraph percent period poration Puerto Rico purchased qualified investments rata share reacquisition real estate investment real property received respect sale or exchange section 959 Statutory provisions stock or securities subdivision subparagraph subpart F income subsection taxable income taxes paid taxpayer tion trade or business trolled foreign corporation United States dollars United States shareholder unused foreign tax
Popular passages
Page 59 - Income from the sale of personal property, see subsection (e). (b) Net income from sources in United States. From the items of gross income specified in subsection (a) of this section there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which can not definitely be allocated to some item or class of gross income.
Page 428 - Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain shall be recognized, but loss shall be recognized. If any part of the money is not so expended...
Page 59 - ... definitely be allocated to some item or class of gross income. The remainder, if any, shall be included in full as net income from sources within the United States. In the case of gross income derived from sources partly within and partly without the United States...
Page 147 - 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 threeyear 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...
Page 93 - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States shall not be included in gross income and shall be exempt from taxation under this chapter.
Page 54 - 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.
Page 54 - ... (B) From a foreign corporation unless less than 50 percent of the gross income of such foreign corporation for the 3-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...
Page 128 - If accrued taxes when paid differ from the amounts claimed as credits by the taxpayer, or if any tax paid is refunded in whole or in part, the taxpayer shall notify the Commissioner, who shall redetermine the amount of the tax for the year or years affected, and the amount of tax due upon such redetermination, if any, shall be paid by the taxpayer upon notice and demand by the collector...
Page 74 - A mere floating intention, indefinite as to time, to return to another country is not sufficient to constitute him a transient. If he lives in the United States and has no definite intention as to his stay, he is a resident. One who comes to the United States for a definite purpose which in its nature may be promptly accomplished is a transient; but, if his purpose is of such a nature that an extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily...
Page 397 - If the property was acquired by gift after December 31, 1920, the basis shall be the same as it would be in the hands of the donor or the last preceding owner by whom it was not acquired by gift...