26 C.F.R. § 1.881-5   Exception for certain possessions corporations.


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
foreign corporations

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§ 1.881-5   Exception for certain possessions corporations.

(a) through (f)(3) [Reserved] For more information, see §1.881–5T(a) through (f)(3).

(f)(4) Bona fide resident

(i) With respect to a particular possession, means—

(A) An individual who is a bona fide resident of the possession as defined in §1.937–1; or

(B) A business entity organized under the laws of the possession and taxable as a corporation in the possession; and

(ii) With respect to the United States, means—

(A) An individual who is a citizen or resident of the United States (as defined under section 7701(b)(1)(A)); or

(B) A business entity organized under the laws of the United States or any State that is classified as a corporation for Federal tax purposes under §301.7701–2(b) of this chapter.

(5) through (7) [Reserved] For more information, see §1.881–5T(f)(5) through (7).

(8) Effective date. This section applies to payments made after January 31, 2006. However, taxpayers may choose to apply this section to all payments made after October 22, 2004 for which the statute of limitations under section 6511 is open.

(g) through (i) [Reserved] For more information, see §1.881–5T(g) through (i).

[T.D. 9248, 71 FR 5001, Jan. 31, 2006]

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