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