Title 26--INTERNAL REVENUE
Chapter I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
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includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
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Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
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Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
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(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
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(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
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(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
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corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
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(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
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income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...
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(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...
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alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
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individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
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of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
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seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
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a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
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a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
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Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
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the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
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the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
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scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
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(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
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(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
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certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
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certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
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Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
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third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
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a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
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in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
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in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
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inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...
...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...
...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...
...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...
...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...
...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...
...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...
...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...
...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...
...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...
...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...
...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...
...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...
...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...
...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


part II (section 871 and following), subchapter N, chapter 1 of the Code, and chapter 3 (section 1441 and following) of the Code, and the regulations thereunder, the...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in paragraph (b) of this section, loss recognized with respect to stock shall be allocated to the class of gross income and, if...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


(a) Foreign tax redeterminations subject to sections 985 through 989 of the Internal Revenue Code. This section applies to a foreign tax redetermination...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


an obligation is principally secured. For purposes of section 860G(a)(3)(A), an obligation is principally secured by an interest in real property only if it...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


of corporations (temporary regulations.) (a) In general. Section 1.861-11T provides special rules for allocating and apportioning interest expense of an...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


part II (section 871 and following), subchapter N, chapter 1 of the Code, and chapter 3 (section 1441 and following) of the Code, and the regulations thereunder, the...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in paragraph (b) of this section, loss recognized with respect to stock shall be allocated to the class of gross income and, if...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


(a) Foreign tax redeterminations subject to sections 985 through 989 of the Internal Revenue Code. This section applies to a foreign tax redetermination...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
...


provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
...


does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


trust or its shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


not satisfy section 857(a)(3)(A) unless-- (1) Part II of subchapter M applied to the trust for all its taxable years beginning after February 28, 1986; and (2) For...


858, a real estate investment trust may elect to treat certain dividends that are distributed within a specified period after the close of a taxable year as having been...


deficiency in (or to be allowed a credit or refund of) certain taxes. ``Qualified investment entity'' is defined in section 860(b). The taxes referred to are those imposed by...


allowed a deduction for a deficiency dividend only if there is a determination (as defined in section 860(e) and paragraph (b)(1) of this section) that results in an...


deficiency dividends with respect to a taxable year, under section 860(c)(1) the tax imposed on the entity by chapter 1 of the Code (computed by taking into account the deduction)...


tax, the taxpayer, in order to secure credit or refund of the overpayment, must file a claim on Form 1120X in addition to the claim for the deficiency dividend deduction...


after November 6, 1978. (b) Prior determination of real estate investments trusts. Section 859 (as in effect before the enactment of the Revenue Act of...


Section 1.860A-1 Effective dates and transition rules. (a) In general. (b) Exceptions. (1) Reporting regulations. (2) Tax...


the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in Sec. 1.860D- 1(c)(3)) whose startup day (as defined in...


a REMIC must take into account the holder's daily portion of the taxable income or net loss of the REMIC for each day during the taxable year on which the holder owned...


taxable income or net loss of a REMIC under section 860C(b), any gain or loss from the disposition of any asset, including a qualified mortgage (as defined in...


as defined in paragraph (c)(3) of this section, that satisfies the requirements of section 860D(a). See paragraph (d)(1) of this section for the manner of electing...


be offset by otherwise allowable deductions--(1) In general. Except as provided in paragraph (a)(3) of this section, the taxable income of any holder of a residual...


of tax. Any excise tax due under section 860E(e)(1) must be paid by the later of March 24, 1993, or April 15th of the year following the calendar year in...


day in the 90-day liquidation period in a statement attached to its final return, then the REMIC will be considered to have adopted a plan of liquidation on the...


formation is characterized as the contribution of assets by a sponsor (as defined in paragraph (b)(1) of this section) to a REMIC in exchange for REMIC regular and...


(c) of this section, for purposes of subtitle F of the Internal Revenue Code, a REMIC is treated as a partnership and any holder of a residual interest in the REMIC...


purposes of section 860G(a)(1), a REMIC designates an interest as a regular interest by providing to the Internal Revenue Service the information specified in...


an obligation is principally secured. For purposes of section 860G(a)(3)(A), an obligation is principally secured by an interest in real property only if it...


general. A transfer of a residual interest that has tax avoidance potential is disregarded for all Federal tax purposes if the transferee is a foreign person. Thus, if a...


N, chapter 1 of the Code, and the regulations thereunder determine the sources of income for purposes of the income tax. These sections explicitly allocate...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...


instrumentality thereof (other than a possession of the United States or an agency or instrumentality of a possession), a State or any political subdivision thereof, or...
...


includes compensation for labor or personal services performed in the United States irrespective of the residence of the payer, the place in which the contract for...


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...


provisions of section 1001 and the regulations thereunder, derived from the sale or other disposition of real property located in the United States. For the treatment of capital...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...


personal property shall be treated as derived entirely from the country in which the property is sold. Thus, gross income from sources within the United States includes gains,...
...


(a) In general. (1) [Reserved] (2) Allocation and apportionment of deductions in general. If an affiliated group of corporations joins in filing a...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...


Sec. 1.861-9T(a) through (g)(1)(i). (g)(1)(ii) [Reserved]. For further guidance, see the second sentence in Sec. 1.861-9T(g)(1)(ii). (g)(1)(iii) through...
...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...


(a)-(c) [Reserved]. For further guidance, see Sec. 1.861-11T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes of this section, in general,...
...
...
...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...


corporations. (a)-(c) [Reserved]. For further guidance, see Sec. 1.861-14T(a) through (c). (d) Definition of affiliated group--(1) General rule. For purposes...
...


taxpayer who owns an aircraft or vessel described in paragraph (b) of this section and who leases the aircraft or vessel to a United States person (other than a member of the...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...


(1) Owns a qualified craft (as defined in paragraph (b) of this section). (2) Leases such qualified craft after December 28, 1980, to a United States person that is not...
...
...


income shall be treated as income from sources without the United States: (i) Interest other than that specified in section 861(a)(1) and Sec. 1.861-2 as being derived...


Sec. 1.863-1 Allocation of gross income. (a) In general. (b) Natural resources. (1) In general. (2) Additional production prior to...


section 861(a) and section 862(a) will generally be separately allocated to sources within or without the United States. See Sec. 1.863-2 for alternate methods to...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...


alternate method for determining taxable income from sources within the United States in the case of gross income derived from sources partly within and partly without...
...


(a) General--(1) Classes of income. Income from the sale of property to which paragraph (b) (2) and (3) of Sec. 1.863-2 applies is divided into two classes for purposes...


(a) [Reserved] (b) Income partly from sources within a foreign country. (1) [Reserved] (2) Allocation or apportionment. ...


than an activity giving rise to transportation income described in section 863(c) or to income subject to other specific provisions of this title) between points in...


Sec. Sec. 1.861-1 to 1.863-5, inclusive, for determining the gross and the taxable income from sources within and without the United States shall generally be applied, for purposes...


Introduction. This section provides rules relating to the source and, in certain cases, the character of notional principal contract income. However, this section does not...


word ``sold'' includes ``exchanged''; the word ``produced'' includes ``created'', ``fabricated'', ``manufactured'', ``extracted'', ``processed'', ``cured'',...


part II (section 871 and following), subchapter N, chapter 1 of the Code, and chapter 3 (section 1441 and following) of the Code, and the regulations thereunder, the...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...


(a) In general. For purposes of the Internal Revenue Code, in the case of a nonresident alien individual or a foreign corporation that is engaged in a trade or business...
...


a nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some time during a taxable year beginning after December...


(a) In general. Income, gain, or loss from sources without the United States which is specified in paragraph (b) of Sec. 1.864-5 and received by a nonresident alien individual or...


determining whether a [[Page 313]] nonresident alien individual or a foreign corporation that is engaged in a trade or business in the United States at some...


for purposes of determining the treatment of income derived by a person from a trade or service receivable acquired from a related person. Except as provided in...


gain. Except as otherwise provided in Sec. 1.865-2 and paragraph (c) of this section, loss recognized with respect to personal property shall be allocated to the...


gain. Except as otherwise provided in paragraph (b) of this section, loss recognized with respect to stock shall be allocated to the class of gross income and, if...


alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as...


residence is not within the United States, and who is not a citizen of the United States. The term includes a nonresident alien fiduciary. For such purpose the...


for purposes of the income tax, it is necessary to decide whether the presumption of nonresidence (as prescribed by paragraph (b) of Sec. 1.871-4) is overcome by facts showing...


or not an alien within the United States has acquired residence therein for purposes of the income tax. (b) Nonresidence presumed. An alien by reason of his alienage,...


a resident until he abandons the same and actually departs from the United States. An intention to change his residence does not change his status as a resident alien to that of...


tax imposed by this section, see chapter 3 of the Internal Revenue Code and the regulations thereunder. [T.D. 8734, 62 FR 53416, Oct. 14,...


applies for purposes of determining the tax of a nonresident alien individual who at no time during the taxable year is engaged in trade or business in the United...


(a) Segregation of income. This section applies for purposes of determining the tax of a nonresident alien individual who at any time during the taxable year is engaged...


or training programs. For purposes of Sec. Sec. 1.871-7 and 1.871-8 a nonresident alien individual who is temporarily present in the United States during the...


be made. A nonresident alien individual or foreign corporation which during the taxable year derives any income from real property which is located in the United States and, in...


purposes of section 871(a)(1)(D), section 881(a)(4), Sec. 1.871-7(c)(1)(iv), Sec. 1.881- 2(c)(1)(iii), and this section, payments which are contingent on the...


Sec. 1.871-7 or Sec. 1.871-8 the tax of a nonresident alien individual, or under Sec. 1.881-2 or Sec. 1.882-1 the tax of a foreign corporation, which for the taxable year...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...


An individual who is a citizen or resident of the United States at the beginning of the taxable year but a nonresident alien at the end of the taxable year, or a nonresident alien...
...


individual for any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for...


rule. So much of the income from sources within the United States of a nonresident alien individual as consists of earnings derived from the operation of a ship or...


the taxable income of a nonresident alien individual the deductions otherwise allowable shall be allowed only if, and to the extent that, they are connected with...


individual shall receive the benefit of the deductions and credits otherwise allowable with respect to the income tax, only if the nonresident alien individual timely...


subsection (a), (b), or (c) of section 871 may depend on the status of the partnership. A nonresident alien individual who is a member of a partnership which is not...


(a) of this section, for any taxable year beginning before January 1, 1975, the grantor of a trust, whether revocable or irrevocable, is not deemed to be...


Puerto Rico during the entire taxable year is, in accordance with the provisions of section 876, subject to tax under section 1 or, in the alternative, under section 1201(b) in...


December 31, 1976, community income of a citizen or resident of the United States who is married to a nonresident alien individual, and the deductions properly allocable...


Sec. 1.881-1 Manner of Taxing Foreign Corporations (a) Classes of foreign corporations. (b) Manner of taxing. (1) Foreign corporations not engaged in...


corporations are divided into two classes, namely, foreign corporations which at no time during the taxable year are engaged in trade or business in the United States...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...


purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also...
...


for the maintenance of records concerning certain financing arrangements to which the provisions of Sec. 1.881-3 apply. (b) Recordkeeping requirements--(1) In general....


1.882-5. Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected ...


income. (a) Segregation of income. This section applies for purposes of determining the tax of a foreign corporation which at any time during the taxable year...


real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any...


any taxable year includes only (i) the gross income which is derived from sources within the United States and which is not effectively connected for the taxable year...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...


corporation that is engaged in, or receives income treated as effectively connected with, a trade or business within the United States is allowed the deductions which...
...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...


1.883-1 Exclusion of income from the international operation of ships or aircraft. (a) General rule. (b) Qualified income. (c) Qualified...
...


of Sec. 1.883-1(c)(2) if it is considered a publicly- traded corporation and satisfies the substantiation and reporting requirements of paragraphs (e) and (f) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...


test of Sec. 1.883-1(c)(2) if it is a controlled foreign corporation (CFC), as defined in section 957(a), and satisfies the income inclusion test in paragraph (b) of...
...


seeking qualified foreign corporation status beginning 30 days or more after August 26, 2003. (b) Election for retroactive application. Taxpayers may elect to apply...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...


branch profits tax on certain earnings of a foreign corporation's U.S. trade or business; a branch-level interest tax on interest paid, or deemed paid, by a...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...


a foreign corporation or its domestic subsidiary. (a) through (a)(2)(i) [Reserved] For further information, see Sec. 1.884-2T(a) through (a)(2)(ii). ...
...
...
...


Doubling of rates of tax on citizens and corporations of certain foreign countries. Whenever the President finds that, under the laws of any foreign country, citizens...


respect to the taxation of income derived by foreign governments and international organizations from sources within the United States. Under section 892, certain specific...


means only the integral parts or controlled entities of a foreign sovereign. (2) Integral part. An ``integral part'' of a foreign sovereign is any...


the exceptions contained in Sec. Sec. 1.892-4T and 1.892-5T for income derived from the conduct of a commercial activity or received from or by a controlled commercial...


(as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income derived from the conduct of a commercial activity or income received by...


(3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in...


a foreign government (as defined in Sec. 1.892-2T) for income described in Sec. 1.892-3T does not apply to income received by a controlled commercial entity or received...


section 1 of the International Organizations Immunities Act (22 U.S.C. 288) (the provisions of which are set forth in paragraph (b)(3) of Sec. 1.893-1), the income of...


government'' referred to in section 893 (relating to the exemption for compensation of employees of foreign governments) has the same meaning as given such term in...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...


Exempt from tax. Except to the extent that the exemption is limited by the execution and filing of the waiver provided for in section 247(b) of the Immigration...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...


the United States or from bank deposits. (a) In general. Income derived by a foreign central bank of issue from obligations of the United States or of any agency...
...
...


scope. This section provides rules pursuant to which a foreign corporation may elect under section 897(i) to be treated as a domestic corporation for purposes of sections...


(a) Purpose and scope. (b) Distributions by domestic corporations. (1) Limitation of basis upon dividend distribution of U.S. real property interest. (2)...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...


(d)(1)(iii)(E). (d)(1)(iii)(F) Identification by name and address of the distributee or transferee, including the distributee's or transferee's taxpayer...
...
...


(a) Rule. Pursuant to section 897(g), an interest in a partnership in which, directly or indirectly, fifty percent or more of the value of the gross...


(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of...


international organizations (temporary). (a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...


certain aliens resident in the United States, domestic corporations, and certain aliens resident in the United States or Puerto Rico may choose to claim a credit, as provided...
...
...
...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...


Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and...
...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...


third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. 1.902-1. (a) Carryback of deficits in post-1986...
...


a less developed country corporation. (a) In general. If a domestic shareholder receives a distribution from a first-tier corporation before January 1, 1978, in...


excess profits taxes'' shall include a tax paid in lieu of a tax on income, war profits, or excess profits (``income tax'') otherwise generally imposed by any foreign country....


the Internal Revenue Code of 1986. Sec. 1.904-1 Limitation on credit for foreign taxes. (a) Per-country limitation. (1) General. ...


does not elect the overall limitation under section 904(a)(2), the amount allowable as a credit for income or profits taxes paid or accrued to a foreign country or a...


chooses to claim a credit under section 901 for a taxable year is allowed a credit under [[Page 679]] that section not only for taxes otherwise allowable as...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...


in addition to those prescribed in Sec. 1.904-2, for the carryback and carryover of the unused foreign tax paid or accrued to a foreign country or possession by a...
...
...
...


inclusions of earnings of a controlled foreign corporation accumulated in taxable years beginning before January 1, 1987, during taxable years of both the payor controlled...


credit limitation of corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income of a corporation from sources without the...


credit limitation of persons other than corporations, the following rules apply: (1) Inclusion in foreign source taxable income. The taxable income from sources...


shall be included as gain from sources within the United States any gain from sources without the United States arising from the sale or exchange of a capital asset...


[Code of Federal Regulations] [Title 26, Volume 9] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.904(b)-4] [Page 747] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.904(b)-4 Effective date. Sections 1.904(b)-(1) and 1.904(b)-2 shall apply to taxable years beginning after December 31, 1975 and Sec. 1.904(b)-3 shall apply to sales and exchanges made after November 12, 1975. [T.D. 7914, 48 FR 44525, Sept. 29, 1983] ...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...


904(f) and these regulations apply to any taxpayer that sustains an overall foreign loss (as defined in paragraph (c)(1) of this section) in a taxable year beginning...
...


and carryovers that include overall foreign losses. If a taxpayer sustains an overall foreign loss that is part of a net operating loss for the year, then, in...


a taxpayer receives a distribution of foreign source taxable income subject to a separate limitation in which the taxpayer had a balance in an overall foreign loss account and...


provided in this section, the rules contained in Sec. Sec. 1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of...


beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982. (a)...


incurred in taxable years beginning before January 1, 1987--(1) In general. If a taxpayer has a balance in an overall foreign loss account at the end of its last taxable...


two or more includible corporations are affiliates, within the meaning of paragraph (b)(1) of this section, at any time during their taxable years, then, solely for purposes...


following), part III, subchapter N, chapter 1 of the Code, may ordinarily be taken either in the return for the year in which the taxes accrued or in which the taxes were...


paragraph (d) of Sec. 1.901-1, to claim the benefits of the foreign tax credit, the claim for credit shall be accompanied by Form 1116 in the case of an individual or...


(a) Foreign tax redeterminations subject to sections 985 through 989 of the Internal Revenue Code. This section applies to a foreign tax redetermination...


The rules of this section shall apply if, as a result of a foreign tax redetermination as defined in Sec. 1.905-3T(c), a redetermination of United States tax liability...


years beginning prior to January 1, 1987 (temporary). (a) In general. This section sets forth rules governing the application of section 905(c) to foreign...


through 1.907(f)-1. Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982). (a)...


Sec. Sec. 1.907(a)-0 through 1.907(f)-1 apply to taxable years beginning after December 31, 1982. For provisions that apply to taxable years beginning before January 1,...


reduction. FOGEI taxes are reduced by the amount by which they exceed a limitation level (as defined in paragraph (c) of this section). (b) Foreign taxes paid or...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...


imposing a FORI tax (as defined in Sec. 1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally...
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provides rules relating to certain items listed in section 907(c)(3). The rules of this section are expressed in terms of FORI but apply for determining FOGEI by...


and apportionment--(1) Scope. Paragraphs (a) (2) through (6) of this section provides rules for the characterization, allocation, and apportionment of the income...


1982). (a) In general--(1) Scope. Section 907(d) applies if a person has FOGEI from the-- (i) Acquisition (other than from a foreign government) or ...


each begin after December 31, 1982). (a) In general. If a taxpayer chooses the benefits of section 901, any unused FOGEI tax paid or accrued in a taxable...


Regulated Investment Companies and Real Estate Investment Trusts Sec. 1.851-1 Definition of regulated investment company. 1.851-2 Limitations. 1.851-3 Rules...


corporation, even though it satisfies the other requirements of part I, subchapter M, chapter 1 of the Code, for the taxable year, will not be considered a regulated...


any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of...


investments and the requirements of section 851(b)(4) and paragraph (c) of Sec. 1.851-2, or the effect that the elimination of such discrepancies will have on the status of...


Investment Company W at the close of its first quarter of the taxable year has its assets invested as follows: ...


the case of a regulated investment company which furnishes capital to development corporations, section 851 (e) provides an exception to the rule relating to the diversification...


(as defined in paragraph (d) of this section) shall not be treated as a person (as defined in section 7701(a)(1)) except for years ending before January 1, 1969. A holder of...


the application of the provisions of part I, subchapter M, chapter 1 of the Code (other than section 852(c), relating to earnings and profits), to a regulated...


a normal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the investment company taxable income, as defined in section 852(b)(2)...


of the investment company to investment company taxable income, as follows: (a) The excess, if any, of the net long-term capital gain over the net short-term...


otherwise provided in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a regulated investment company shall include such...


company meets the requirements of section 852(a) and paragraphs (a)(1) (i) and (ii) of Sec. 1.852-1, shall apply paragraph (b) of this section in computing its earnings...


a personal holding company. (a) Every regulated investment company shall maintain in the internal revenue district in which it is required to file its income...


demand of a regulated investment company for the written statements which Sec. 1.852-6 requires the company to demand from its shareholders shall submit as a part of his income...


or their shareholders from the duty of filing information returns required by regulations prescribed under the provisions of subchapter A, chapter 61 of...


Notice to shareholders. (i) A designation of undistributed capital gains under section 852(b)(3)(D) and paragraph (b)(2)(i) of Sec. 1.852-2 shall be made by notice...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...


of the excess of its net long-term capital gain over net short-term capital loss on which it must pay a capital gains tax, a regulated investment company is allowed...
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does not satisfy section 852(a)(2)(A) unless-- (i) Part I of subchapter M applied to the company for all its taxable years ending on or after November 8, 1983; and ...


the requirements set forth in section 853(a) and paragraph (b) of this section, may make an election with respect to the income, war- profits, and excess profits...


respect to a taxable year under the provisions of section 853(a) is, for such year, denied both the deduction for foreign taxes provided by section 164(a) and the...


in the manner provided in Sec. 1.853-4, the investment company is required, under section 853(c), to furnish its shareholders with a written notice mailed not later than 45...


section 853, must-- [[Page 45]] (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i)...


provides special limitations applicable to dividends received from a regulated investment company for purposes of the exclusion under section 116 for dividends received...


treat as a dividend for purposes of the exclusion under section 116 for dividends received by individuals, the deduction under section 243 for dividends received by corporation,...


of Sec. 1.854-1, the term ``gross income'' does not include gain from the sale or other disposition of stock or securities. However, capital gains arising from the sale...


(1) Determining under section 852(a) and paragraph (a) of Sec. 1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by...


the amendments made by the Revenue Act of 1978, other than the changes made by section 362 of the Act, relating to deficiency dividends. (Sec. 856(d)(4) (90...


corporation, trust, or association which (1) meets the status conditions in section 856(a) and paragraph (b) of this section, and (2) satisfies the gross income and...


thereunder apply only to taxable years of a real estate investment trust beginning after December 31, 1960. (b) Election. Under the provisions of section 856(c)(1),...


shall apply. (a) Value. The term ``value'' means, with respect to securities for which market quotations are readily available, the market value of...


this section, the term ``rents from real property'' means, generally, the gross amounts received for the use of, or the right to use, real property of the real estate...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...


term ``interest'' includes only an amount which constitutes compensation for the use or forbearance of money. For example, a fee received or accrued by a lender which is in fact...
...


corporation, trust, or association which fails to meet the requirements of paragraph (2) or (3) of section 856(c), or of both such paragraphs, for any taxable year nevertheless...


corporation, trust, or association that has made an election under section 856(c)(1) [[Page 74]] to be a real estate investment trust may revoke the election for...


the provisions of part II, subchapter M, chapter 1 of the Code (other than sections 856(g), relating to the revocation or termination of an election, and 857(d),...


Section 857(b)(1) imposes a nominal tax and surtax, computed at the rates and in the manner prescribed in section 11, on the ``real estate investment trust...


property means the aggregate of-- (1) All gains and losses from sales or other dispositions of foreclosure property described in section 1221(1), and, (2)...


a tax on a real estate investment trust that is considered, by reason of section 856(c)(7), as meeting the source-of-income requirements of paragraph (2)...


a tax equal to 100 percent of the net income derived from prohibited transactions. A prohibited transaction is a sale or other disposition of property described in...


in paragraph (b) of this section (relating to capital gains), a shareholder receiving dividends from a real estate investment trust shall include such dividends...


trust meets the requirements of section 857(a) and paragraph (a) of Sec. 1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this...


trust is required to keep such records as will disclose the actual ownership of its outstanding stock. Thus, every real estate investment trust shall maintain in...


a real estate investment trust the written statements required under Sec. 1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files...


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