Code of Federal Regulations, Title 26, Internal Revenue, PT. 1 (Sections 1.851-1.907), Revised as of April 1, 2012U S Office of the Federal Register |
Common terms and phrases
activity adjusted basis affiliated group allocated amount apply apportioned apportionment attributable capital loss computed controlled foreign corporation debt December 31 deduction dends described in paragraph described in section deter determined domestic corporation earnings and profits effectively connected election entity estate investment trust Example exempt filed foreign cor foreign country foreign source foreign tax credit graph gross income income derived income from sources income tax treaty indebtedness interest expense Internal Revenue Service liabilities loan ment method mortgage nonresident alien individual obligation paid paragraph b)(1 partnership payment percent period poration post-October pursuant qualified real estate investment real property received related person REMIC resident residual interest respect share ship source income Special rule spect statutory grouping subparagraph taxable income taxable years beginning taxpayer terest tion trade or business transaction transfer treated U.S. assets U.S. dollars U.S. shareholder U.S. source unit investment trust United