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property to foreign persons
Special categories of corporate tax treatment
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allowed amount of foreign argued assets beginning after December billion capital gains income China Trade Act controlled foreign corporation CTA corporation December 31 developed country corporation DISC benefits distributed domestic corporation earned abroad excise tax exclusion exemption export sales foreign country foreign income foreign source income foreign subsidiary foreign tax credit foreign taxes paid foreign trusts gross income Hong Kong House bill income earned income from sources income tax Internal Revenue Service investment Law Under present less developed country losses ordinary income overall limitation per-country limitation percent Petroleum possessions corporation provision would apply Puerto Rico reduce U.S. tax repealed residents section 367 special deduction special dividend tax haven income tax rate Tax Reduction Act tax treatment taxable income taxable years beginning tion trade or business transaction transfers of property U.S. citizens U.S. corporations U.S. person U.S. shareholders U.S. tax liability U.S. taxpayer United WHTC worldwide income