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Introductory Remarks and Definitions
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acquired foreign corporation acquisition advance ruling allocation amount apply assets basis capital gains Chicle controlled foreign corporation deemed paid described in section developed country corporation dividend domestic corporation earnings and profits effective foreign tax election exclusion exempt favorable ruling Federal income tax foreign base company foreign cor foreign personal holding foreign subsidiary foreign tax credit foreign tax rate FPHC Fund gross income guidelines Internal Revenue Code invested in U.S. IRC Section issued ldcc less developed country lower tier corporation minimum distribution Netherlands Antilles ownership parent percent personal holding company poration proﬁts provides reorganization Revenue Procedure ruling under section section 367 shares source income stock or securities Subpart F income tainted tax avoidance tax treaties taxation taxpayer tion trade or business transaction transfer transferor U. S. property U.S. person U.S. shareholder U.S. tax United States persons United States shareholder