26 C.F.R. PART 1--INCOME TAXES


TITLE 26--Internal Revenue

CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY

SUBCHAPTER A--INCOME TAX

PART 1--INCOME TAXES

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Table of Contents
       Headings
1.908
[Reserved]
1.911-1
Partial exclusion for earned income from sources within a foreign country and foreign housing costs.
1.911-2
Qualified individuals.
1.911-3
Determination of amount of foreign earned income to be excluded.
1.911-4
Determination of housing cost amount eligible for exclusion or deduction.
1.911-5
Special rules for married couples.
1.911-6
Disallowance of deductions, exclusions, and credits.
1.911-7
Procedural rules.
1.911-8
Former deduction for certain expenses of living abroad.
1.912-1
Exclusion of certain cost-of-living allowances.
1.912-2
Exclusion of certain allowances of Foreign Service personnel.
1.921-1t
Temporary regulations providing transition rules for DISCs and FSCs.
1.921-2
Foreign Sales Corporation--general rules.
1.921-3t
Temporary regulations; Foreign sales corporation general rules.
1.922-1
Requirements that a corporation must satisfy to be a FSC or a small FSC.
1.923-1t
Temporary regulations; exempt foreign trade income.
1.924(a)-1t
Temporary regulations; definition of foreign trading gross receipts.
1.924(c)-1
Requirement that a FSC be managed outside the United States.
1.924(d)-1
Requirement that economic processes take place outside the United States.
1.924(e)-1
Activities relating to the disposition of export property.
1.925(a)-1
Transfer pricing rules for FSCs.
1.925(a)-1t
Temporary regulations; transfer pricing rules for FSCs.
1.925(b)-1t
Temporary regulations; marginal costing rules.
1.926(a)-1
Distributions to shareholders.
1.926(a)-1t
Temporary regulations; distributions to shareholders.
1.927(a)-1t
Temporary regulations; definition of export property.
1.927(b)-1t
Temporary regulations; Definition of gross receipts.
1.927(d)-1
Other definitions.
1.927(d)-2t
Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.
1.927(e)-1
Special sourcing rule.
1.927(e)-2t
Temporary regulations; effect of boycott participation on FSC and small FSC benefits.
1.927(f)-1
Election and termination of status as a Foreign Sales Corporation.
1.931-1
Exclusion of certain income from sources within Guam, American Samoa, or the Northern Mariana Islands.
1.931-1t
Exclusion of certain income from sources within Guam, American Samoa, or the Northern Mariana Islands (temporary).
1.932-1
Coordination of United States and Virgin Islands income taxes.
1.932-1t
Coordination of United States and Virgin Islands income taxes (temporary).
1.933-1
Exclusion of certain income from sources within Puerto Rico.
1.933-1t
Exclusion of certain income from sources within Puerto Rico (temporary).
1.934-1
Limitation on reduction in income tax liability incurred to the Virgin Islands.
1.934-1t
Limitation on reduction in income tax liability incurred to the Virgin Islands (temporary).
1.935-1
Coordination of individual income taxes with Guam and the Northern Mariana Islands.
1.935-1t
Coordination of individual income taxes with Guam and the Northern Mariana Islands (temporary).
1.936-1
Elections.
1.936-4
Intangible property income in the absence of an election out.
1.936-5
Intangible property income when an election out is made: Product, business presence, and contract manufacturing.
1.936-6
Intangible property income when an election out is made: Cost sharing and profit split options; covered intangibles.
1.936-7
Manner of making election under section 936 (h)(5); special election for export sales; revocation of election under section 936(a).
1.936-7t
Manner of making election under section 936(h)(5); special election for export sales; revocation of election under section 936(a) (temporary).
1.936-8t
Qualified possession source investment income (temporary).--[Reserved]
1.936-9t
Source of qualified possession source investment income (temporary).--[Reserved]
1.936-10
Qualified investments.
1.936-11
New lines of business prohibited.
1.937-1
Bona fide residency in a possession.
1.937-2t
Income from sources within a possession (temporary).
1.937-3t
Income effectively connected with the conduct of a trade or business in a possession (temporary).
1.941-1
Special deduction for China Trade Act corporations.
1.941-2
Meaning of terms used in connection with China Trade Act corporations.
1.941-3
Illustration of principles.
1.943-1
Withholding by a China Trade Act corporation.
1.951-1
Amounts included in gross income of United States shareholders.
1.951-2
Coordination of subpart F with election of a foreign investment company to distribute income.
1.951-3
Coordination of subpart F with foreign personal holding company provisions.
1.952-1
Subpart F income defined.
1.952-2
Determination of gross income and taxable income of a foreign corporation.
1.953-1
Income from insurance of United States risks.
1.953-2
Actual United States risks.
1.953-3
Risks deemed to be United States risks.
1.953-4
Taxable income to which section 953 applies.
1.953-5
Corporations not qualifying as insurance companies.
1.953-6
Relationship of sections 953 and 954.
1.954-0
Introduction.
1.954-1
Foreign base company income.
1.954-2
Foreign personal holding company income.
1.954-2t
Foreign personal holding company income (temporary).
1.954-3
Foreign base company sales income.
1.954-4
Foreign base company services income.
1.954-5
Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976.
1.954-6
Foreign base company shipping income.
1.954-7
Increase in qualified investments in foreign base company shipping operations.
1.954-8
Foreign base company oil related income.
1.955-0
Effective dates.
1.955-1
Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries.
1.955-2
Amount of a controlled foreign corporation's qualified investments in less developed countries.
1.955-3
Election as to date of determining qualified investments in less developed countries.
1.955-4
Definition of less developed country.
1.955-5
Definition of less developed country corporation.
1.955-6
Gross income from sources within less developed countries.
1.955a-1
Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in foreign base company shipping operations.
1.955a-2
Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations.
1.955a-3
Election as to qualified investments by related persons.
1.955a-4
Election as to date of determining qualified investment in foreign base company shipping operations.
1.956-1
Shareholder's pro rata share of a controlled foreign corporation's increase in earnings invested in United States property.
1.956-1t
Shareholder's pro rata share of a controlled foreign corporation's increase in earnings invested in United States property (temporary).
1.956-2
Definition of United States property.
1.956-2t
Definition of United States Property (temporary).
1.956-3t
Certain trade or service receivables acquired from United States persons (temporary).
1.957-1
Definition of controlled foreign corporation.
1.957-2
Controlled foreign corporation deriving income from insurance of United States risks.
1.957-3
United States person defined.
1.957-3t
United States person defined (temporary).
1.958-1
Direct and indirect ownership of stock.
1.958-2
Constructive ownership of stock.
1.959-1
Exclusion from gross income of United States persons of previously taxed earnings and profits.
1.959-2
Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits.
1.959-3
Allocation of distributions to earnings and profits of foreign corporations.
1.959-4
Distributions to United States persons not counting as dividends.
1.960-1
Foreign tax credit with respect to taxes paid on earnings and profits of controlled foreign corporations.
1.960-2
Interrelation of section 902 and section 960 when dividends are paid by third-, second-, or first-tier corporation.
1.960-3
Gross-up of amounts included in income under section 951.
1.960-4
Additional foreign tax credit in year of receipt of previously taxed earnings and profits.
1.960-5
Credit for taxable year of inclusion binding for taxable year of exclusion.
1.960-6
Overpayments resulting from increase in limitation for taxable year of exclusion.
1.960-7
Effective dates.
1.961-1
Increase in basis of stock in controlled foreign corporations and of other property.
1.961-2
Reduction in basis of stock in foreign corporations and of other property.
1.962-1
Limitation of tax for individuals on amounts included in gross income under section 951(a).
1.962-2
Election of limitation of tax for individuals.
1.962-3
Treatment of actual distributions.
1.962-4
Transitional rules for certain taxable years.
1.963-0
Repeal of section 963; effective dates.
1.963-1
Exclusion of subpart F income upon receipt of minimum distribution.
1.963-2
Determination of the amount of the minimum distribution.
1.963-3
Distributions counting toward a minimum distribution.
1.963-4
Limitations on minimum distribution from a chain or group.
1.963-5
Foreign corporations with variation in foreign tax rate because of distributions.
1.963-6
Deficiency distribution.
1.963-7
Transitional rules for certain taxable years.
1.963-8
Determination of minimum distribution during the surcharge period.
1.964-1
Determination of the earnings and profits of a foreign corporation.
1.964-1t
Determination of the earnings and profits of a foreign corporation (temporary).
1.964-2
Treatment of blocked earnings and profits.
1.964-3
Records to be provided by United States shareholders.
1.964-4
Verification of certain classes of income.
1.964-5
Effective date of subpart F.
1.970-1
Export trade corporations.
1.970-2
Elections as to date of determining investments in export trade assets.
1.970-3
Effective date of subpart G.
1.971-1
Definitions with respect to export trade corporations.
1.972-1
Consolidation of group of export trade corporations.
1.981-0
Repeal of section 981; effective dates.
1.981-1
Foreign law community income for taxable years beginning after December 31, 1966, and before January 1, 1977.
1.981-2
Foreign law community income for taxable years beginning before January 1, 1967.
1.981-3
Definitions and other special rules.
1.985-0
Outline of regulation.
1.985-1
Functional currency.
1.985-2
Election to use the United States dollar as the functional currency of a QBU.
1.985-3
United States dollar approximate separate transactions method.
1.985-4
Method of accounting.
1.985-5
Adjustments required upon change in functional currency.
1.985-6
Transition rules for a QBU that uses the dollar approximate separate transactions method for its first taxable year beginning in 1987.
1.985-7
Adjustments required in connection with a change to DASTM.
1.985-8
Special rules applicable to the European Monetary Union (conversion to euro).
1.987-1
Profit and loss method of accounting for a qualified business unit of a taxpayer having a different functional currency from the taxpayer.--[Reserved]
1.987-2
Accounting for gain or loss on certain transfers of property.--[Reserved]
1.987-3
Termination.--[Reserved]
1.987-4
Special rules relating to QBU branches of foreign taxpayers.--[Reserved]
1.987-5
Transition rules for certain qualified business units using a profit and loss method of accounting for taxable years beginning before January 1, 1987.
1.988-0
Taxation of gain or loss from a section 988 transaction; Table of Contents.
1.988-1
Certain definitions and special rules.
1.988-2
Recognition and computation of exchange gain or loss.
1.988-3
Character of exchange gain or loss.
1.988-4
Source of gain or loss realized on a section 988 transaction.
1.988-5
Section 988(d) hedging transactions.
1.988-6
Nonfunctional currency contingent payment debt instruments.
1.989(a)-1
Definition of a qualified business unit.
1.989(b)-1
Definition of weighted average exchange rate.
1.989(c)-1
Transition rules for certain branches of United States persons using a net worth method of accounting for taxable years beginning before January 1, 1987.
1.991-1
Taxation of a domestic international sales corporation.
1.992-1
Requirements of a DISC.
1.992-2
Election to be treated as a DISC.
1.992-3
Deficiency distributions to meet qualification requirements.
1.992-4
Coordination with personal holding company provisions in case of certain produced film rents.
1.993-1
Definition of qualified export receipts.
1.993-2
Definition of qualified export assets.
1.993-3
Definition of export property.
1.993-4
Definition of producer's loans.
1.993-5
Definition of related foreign export corporation.
1.993-6
Definition of gross receipts.
1.993-7
Definition of United States.
1.994-1
Inter-company pricing rules for DISC's.
1.994-2
Marginal costing rules.
1.995-1
Taxation of DISC income to shareholders.
1.995-2
Deemed distributions in qualified years.
1.995-3
Distributions upon disqualification.
1.995-4
Gain on disposition of stock in a DISC.
1.995-5
Foreign investment attributable to producer's loans.
1.995-6
Taxable income attributable to military property.
1.996-1
Rules for actual distributions and certain deemed distributions.
1.996-2
Ordering rules for losses.
1.996-3
Divisions of earnings and profits.
1.996-4
Subsequent effect of previous disposition of DISC stock.
1.996-5
Adjustment to basis.
1.996-6
Effectively connected income.
1.996-7
Carryover of DISC tax attributes.
1.996-8
Effect of carryback of capital loss or net operating loss to prior DISC taxable year.
1.997-1
Special rules for subchapter C of the Code.
1.998-1.1000
[Reserved]
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