The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1998 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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... attributable to certain notional contracts principal 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 effec- tively connected with U.S. ...
... attributable to certain notional contracts principal 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 effec- tively connected with U.S. ...
10 ÆäÀÌÁö
... attributable to the amounts which were so included in gross section under income 951 ( a ) ( 1 ) ( A ) ( i ) . For allocation of dis- tributions to earnings and profits of foreign corporations , see ¡×1.959-3 . The provisions of this ...
... attributable to the amounts which were so included in gross section under income 951 ( a ) ( 1 ) ( A ) ( i ) . For allocation of dis- tributions to earnings and profits of foreign corporations , see ¡×1.959-3 . The provisions of this ...
31 ÆäÀÌÁö
... attributable to a tax- able year for which an election is in ef- fect under section 4982 ( e ) ( 4 ) of the Code with respect to the company . ( c ) Post - October capital loss defined— ( 1 ) In general . For purposes of this sec- tion ...
... attributable to a tax- able year for which an election is in ef- fect under section 4982 ( e ) ( 4 ) of the Code with respect to the company . ( c ) Post - October capital loss defined— ( 1 ) In general . For purposes of this sec- tion ...
40 ÆäÀÌÁö
... attributable solely to the regulated investment company having made the retroactive election . ( C ) Limitation on capital gain divi- dends . The amount of retroactive divi- dends qualifying as capital gain divi- dends paid for a ...
... attributable solely to the regulated investment company having made the retroactive election . ( C ) Limitation on capital gain divi- dends . The amount of retroactive divi- dends qualifying as capital gain divi- dends paid for a ...
56 ÆäÀÌÁö
... attributable to the real property , shall be deemed gross income from the sale or disposition of real property held for either the period that the partnership has held the real prop- erty of the period that the trust was a member of the ...
... attributable to the real property , shall be deemed gross income from the sale or disposition of real property held for either the period that the partnership has held the real prop- erty of the period that the trust was a member of the ...
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472 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - 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 ÆäÀÌÁö - ... 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 ÆäÀÌÁö - 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...
136 ÆäÀÌÁö - States as provided in subsection (a) (2) of this section; (3) Compensation for labor or personal services performed without the United States; (4) Rentals or royalties from property located without the United States or from any interest in such property...