The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1990 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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adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation December 31 deduction dends determined distribution dividend domestic corporation dual capacity taxpayers earnings and profits effectively connected earnings eign corporation election entity estate investment trust Example fair market value foreign country Foreign income taxes foreign loss account foreign mineral income foreign source foreign tax credit graph gross income income from sources interest expense levy liability limitation income ment nonresident alien individual overall foreign loss paragraph a)(1 partnership passive income payment poration pursuant qualified real estate investment real property holding real property interest received related person resident residual grouping respect source income statutory grouping subdivision subparagraph tax treaty taxable years beginning taxes paid terest tion trade or business treated U.S. assets U.S. real property U.S. tax U.S. trade unit investment trust unused foreign tax X tax
Popularni odlomci
Stranica 293 - In the case of a nonresident alien individual the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States...
Stranica 112 - The labor or services are performed by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year...
Stranica 250 - This subparagraph relates to gross income derived from the sale of personal property produced (in whole or in part) by the taxpayer within the United States and sold within a possession of the United States, or produced (in whole or in part) by the taxpayer within a possession of the United States and sold within the United States.
Stranica 53 - Government securities, securities of other investment companies, and other securities for the purposes of this calculation limited in respect of any one issuer to an amount not greater in value than 5...
Stranica 435 - 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 (li) the taxes deemed to have been paid or accrued under section 902, 905(b), or 960.
Stranica 297 - For purposes of this section, the term "earned income" means wages, salaries, or professional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for personal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered. In the case...
Stranica 251 - Gains, profits and income from (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within...
Stranica 365 - ... (c) INCOME OF FOREIGN GOVERNMENTS AND OF INTERNATIONAL ORGANIZATIONS.— The income of foreign governments or international organizations received from investments in the United States in stocks, bonds, or other domestic securities, owned by such foreign governments or...
Stranica 85 - ... is greater than the excess of the net long-term capital gain over the net short-term capital loss of the taxable year, the portion of each distribution which shall be a capital gain dividend shall be only that proportion of the amount so designated which such excess of the net long-term capital gain over the net short-term capital loss bears to the aggregate amount so designated.
Stranica 113 - ... amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.