The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1996 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 capital loss computed controlled foreign corporation corporation's December 31 deduction described in paragraph determined distribution domestic corporation dual capacity taxpayers earnings and profits effectively connected election entity erty estate investment trust Example fair market value foreign cor foreign corporation foreign income taxes foreign mineral income foreign source foreign tax graph gross income holder income from sources inter interest expense levy liabilities ment nonresident alien individual partnership payment percent poration post-October pursuant qualified real estate investment real property holding real property interest received related person REMIC resident respect share source income spect statutory grouping subparagraph tax treaty taxable income taxable years beginning taxes paid terest tion trade or business transaction treated U.S. assets U.S. dollars U.S. real property U.S. shareholder U.S. tax U.S. trade unit investment trust United X tax
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123 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 cannot definitely be allocated to some item or class of gross income.
322 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...
55 페이지 - At least 75 per centum of the value of its total assets is represented by cash and cash items (including receivables), Government securities, securities of other...
257 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...
64 페이지 - If the determination of such amount depends in whole or in part on the income or profits derived by any person from such property (except that any amount so received or accrued shall not be excluded from the term "rents from real property...
264 페이지 - States shall not be deemed to be income from sources within the United 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...
570 페이지 - For purposes of this subpart and of sections 164(a) and 275(a), the term "income, war profits, and excess profits taxes" shall include a tax paid in lieu of a tax on. income, war profits, or excess profits otherwise generally imposed by any foreign country or by any possession of the United States.
467 페이지 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
25 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.
565 페이지 - ... accumulated profits of the preceding year or years (unless to his satisfaction shown otherwise), and in other respects treating dividends as having been paid from the most recently accumulated gains, profits, or earnings.