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able activities adjusted alien allocated allowed amount apply apportioned apportionment assets attributable bank basis beginning branch Code computed conduct considered controlled debt deduction defined derived described determined distribution dividend domestic earnings and profits effectively election engaged entity Example excess exchange expense facts fair market value filed financing foreign corporation gain graph gross income held holder holding imposed income tax individual inter interest interest expense investment issued levy liabilities limitation loss meaning ment method nonresident obligation paid paragraph partnership payment percent period person poration portion principal production pursuant qualified real estate real property interest reason received regulations REMIC resident respect rules securities share shareholder sources specified Stat statement taxable income taxpayer term tion trade or business transaction treated trust U.S. real property United
472 페이지 - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.
122 페이지 - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income.
267 페이지 - 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...
542 페이지 - States, whether resident or nonresident, may claim a credit for (i) the amount of any income, war profits, and excess profits taxes paid or accrued (or deemed paid or accrued under section 905(b)) during- the taxable year to any foreign country or to any possession of the United States: and (ii) his share of any such taxes of a partnership of which he is a member.
340 페이지 - 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; and the proper apportionment and allocation of the deductions with respect to sources of income within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary.
376 페이지 - Persons entitled to the benefits of this section shall not be allowed the credits against the tax for taxes of foreign countries and possessions of the United States allowed by section 901.
289 페이지 - 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; and (5) Sale of real property.
82 페이지 - ... 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.
273 페이지 - States if— (A) 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...