Title 26--Internal Revenue
CHAPTER I--INTERNAL REVENUE SERVICE,
DEPARTMENT OF THE TREASURY (CONTINUED)
PART 1--INCOME TAXES
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| 1.911-1 |
Partial exclusion for earned income from sources within a foreign country and foreign housing costs. |
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| 1.911-2 |
Qualified individuals. |
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| 1.911-3 |
Determination of amount of foreign earned income to be excluded. |
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| 1.911-4 |
Determination of housing cost amount eligible for exclusion or deduction. |
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| 1.911-5 |
Special rules for married couples. |
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| 1.911-6 |
Disallowance of deductions, exclusions, and credits. |
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| 1.911-7 |
Procedural rules. |
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| 1.911-8 |
Former deduction for certain expenses of living abroad. |
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| 1.912-1 |
Exclusion of certain cost-of-living allowances. |
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| 1.912-2 |
Exclusion of certain allowances of Foreign Service personnel. |
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| 1.921-1T |
Temporary regulations providing transition rules for DISCs and FSCs.
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| 1.921-2 |
Foreign Sales Corporation--general rules. |
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| 1.921-3T |
Temporary regulations; Foreign sales corporation general rules. |
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| 1.922-1 |
Requirements that a corporation must satisfy to be a FSC or a small FSC. |
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| 1.923-1T |
Temporary regulations; exempt foreign trade income. |
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| 1.924(a)-1T |
Temporary regulations; definition of foreign trading gross receipts. |
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| 1.924(c)-1 |
Requirement that a FSC be managed outside the United States. |
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| 1.924(d)-1 |
Requirement that economic processes take place outside the United States. |
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| 1.924(e)-1 |
Activities relating to the disposition of export property. |
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| 1.925(a)-1 |
Transfer pricing rules for FSCs. |
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| 1.925(a)-1T |
Temporary regulations; transfer pricing rules for FSCs. |
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| 1.925(b)-1T |
Temporary regulations; marginal costing rules.
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| 1.926(a)-1 |
Distributions to shareholders. |
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| 1.926(a)-1T |
Temporary regulations; distributions to shareholders. |
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| 1.927(a)-1T |
Temporary regulations; definition of export property. |
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| 1.927(b)-1T |
Temporary regulations; Definition of gross receipts. |
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| 1.927(d)-1 |
Other definitions. |
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| 1.927(d)-2T |
Temporary regulations; definitions and special rules relating to Foreign Sales Corporation. |
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| 1.927(e)-1 |
Special sourcing rule. |
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| 1.927(e)-2T |
Temporary regulations; effect of boycott participation on FSC and small FSC benefits. |
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| 1.927(f)-1 |
Election and termination of status as a Foreign Sales Corporation. |
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| 1.931-1 |
Citizens of the United States and domestic corporations deriving income from sources within a certain possession of the United States. |
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| 1.932-1 |
Status of citizens of U.S. possessions. |
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| 1.933-1 |
Exclusion of certain income from sources within Puerto Rico. |
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| 1.934-1 |
Limitation on reduction in income tax liability incurred to the Virgin Islands. |
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| 1.935-1 |
Coordination of U.S. and Guam individual income taxes. |
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| 1.936-1 |
Elections. |
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| 1.936-4 |
Intangible property income in the absence of an election out. |
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| 1.936-5 |
Intangible property income when an election out is made: Product, business presence, and contract manufacturing. |
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| 1.936-6 |
Intangible property income when an election out is made: Cost sharing and profit split options; covered intangibles. |
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| 1.936-7 |
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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| 1.936-10 |
Qualified investments. |
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| 1.936-11 |
New lines of business prohibited. |
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| 1.941-1 |
Special deduction for China Trade Act corporations. |
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| 1.941-2 |
Meaning of terms used in connection with China Trade Act corporations. |
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| 1.941-3 |
Illustration of principles. |
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| 1.943-1 |
Withholding by a China Trade Act corporation. |
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| 1.951-1 |
Amounts included in gross income of United States shareholders. |
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| 1.951-2 |
Coordination of subpart F with election of a foreign investment company to distribute income. |
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| 1.951-3 |
Coordination of subpart F with foreign personal holding company provisions. |
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| 1.952-1 |
Subpart F income defined. |
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| 1.952-2 |
Determination of gross income and taxable income of a foreign corporation. |
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| 1.953-1 |
Income from insurance of United States risks. |
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| 1.953-2 |
Actual United States risks. |
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| 1.953-3 |
Risks deemed to be United States risks. |
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| 1.953-4 |
Taxable income to which section 953 applies. |
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| 1.953-5 |
Corporations not qualifying as insurance companies. |
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| 1.953-6 |
Relationship of sections 953 and 954. |
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| 1.954-0 |
Introduction. |
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| 1.954-1 |
Foreign base company income. |
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| 1.954-2 |
Foreign personal holding company income.
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| 1.954-3 |
Foreign base company sales income. |
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| 1.954-4 |
Foreign base company services income. |
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| 1.954-5 |
Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976. |
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| 1.954-6 |
Foreign base company shipping income. |
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| 1.954-7 |
Increase in qualified investments in foreign base company shipping operations. |
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| 1.954-8 |
Foreign base company oil related income. |
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| 1.955-0 |
Effective dates. |
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| 1.955-1 |
Shareholder's pro rata share of amount of previously excluded subpart F income withdrawn from investment in less developed countries. |
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| 1.955-2 |
Amount of a controlled foreign corporation's qualified investments in less developed countries. |
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| 1.955-3 |
Election as to date of determining qualified investments in less developed countries. |
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| 1.955-4 |
Definition of less developed country. |
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| 1.955-5 |
Definition of less developed country corporation. |
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| 1.955-6 |
Gross income from sources within less developed countries. |
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| 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. |
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| 1.955A-2 |
Amount of a controlled foreign corporation's qualified investments in foreign base company shipping operations. |
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| 1.955A-3 |
Election as to qualified investments by related persons. |
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| 1.955A-4 |
Election as to date of determining qualified investment in foreign base company shipping operations. |
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| 1.956-1 |
Shareholder's pro rata share of a controlled foreign corporation's increase in earnings invested in United States property. |
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| 1.956-1T |
Shareholder's pro rata share of a controlled foreign corporation's increase in earnings invested in United States property (temporary). |
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| 1.956-2 |
Definition of United States property. |
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| 1.956-2T |
Definition of United States Property (temporary). |
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| 1.956-3T |
Certain trade or service receivables acquired from United States persons (temporary). |
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| 1.957-1 |
Definition of controlled foreign corporation. |
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| 1.957-2 |
Controlled foreign corporation deriving income from insurance of United States risks. |
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| 1.957-3 |
Corporations organized in United States possessions. |
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| 1.957-4 |
United States person defined. |
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| 1.958-1 |
Direct and indirect ownership of stock. |
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| 1.958-2 |
Constructive ownership of stock. |
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| 1.959-1 |
Exclusion from gross income of United States persons of previously taxed earnings and profits. |
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| 1.959-2 |
Exclusion from gross income of controlled foreign corporations of previously taxed earnings and profits. |
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| 1.959-3 |
Allocation of distributions to earnings and profits of foreign corporations. |
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| 1.959-4 |
Distributions to United States persons not counting as dividends. |
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| 1.960-1 |
Foreign tax credit with respect to taxes paid on earnings and profits of controlled foreign corporations. |
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| 1.960-2 |
Interrelation of section 902 and section 960 when dividends are paid by third-, second-, or first-tier corporation. |
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| 1.960-3 |
Gross-up of amounts included in income under section 951. |
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| 1.960-4 |
Additional foreign tax credit in year of receipt of previously taxed earnings and profits. |
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| 1.960-5 |
Credit for taxable year of inclusion binding for taxable year of exclusion. |
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| 1.960-6 |
Overpayments resulting from increase in limitation for taxable year of exclusion. |
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| 1.960-7 |
Effective dates. |
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| 1.961-1 |
Increase in basis of stock in controlled foreign corporations and of other property. |
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| 1.961-2 |
Reduction in basis of stock in foreign corporations and of other property. |
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| 1.962-1 |
Limitation of tax for individuals on amounts included in gross income under section 951(a). |
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| 1.962-2 |
Election of limitation of tax for individuals. |
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| 1.962-3 |
Treatment of actual distributions. |
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| 1.962-4 |
Transitional rules for certain taxable years. |
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| 1.963-0 |
Repeal of section 963; effective dates. |
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| 1.963-1 |
Exclusion of subpart F income upon receipt of minimum distribution. |
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| 1.963-2 |
Determination of the amount of the minimum distribution. |
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| 1.963-3 |
Distributions counting toward a minimum distribution. |
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| 1.963-4 |
Limitations on minimum distribution from a chain or group. |
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| 1.963-5 |
Foreign corporations with variation in foreign tax rate because of distributions. |
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| 1.963-6 |
Deficiency distribution. |
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| 1.963-7 |
Transitional rules for certain taxable years. |
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| 1.963-8 |
Determination of minimum distribution during the surcharge period. |
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| 1.964-1 |
Determination of the earnings and profits of a foreign corporation. |
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| 1.964-1T |
Special rules for computing earnings and profits of controlled foreign corporations in taxable years beginning after December 31, 1986 (temporary). |
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| 1.964-2 |
Treatment of blocked earnings and profits. |
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| 1.964-3 |
Records to be provided by United States shareholders. |
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| 1.964-4 |
Verification of certain classes of income. |
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| 1.964-5 |
Effective date of subpart F. |
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| 1.970-1 |
Export trade corporations. |
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| 1.970-2 |
Elections as to date of determining investments in export trade assets. |
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| 1.970-3 |
Effective date of subpart G. |
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| 1.971-1 |
Definitions with respect to export trade corporations. |
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| 1.972-1 |
Consolidation of group of export trade corporations. |
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| 1.981-0 |
Repeal of section 981; effective dates. |
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| 1.981-1 |
Foreign law community income for taxable years beginning after December 31, 1966, and before January 1, 1977. |
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| 1.981-2 |
Foreign law community income for taxable years beginning before January 1, 1967. |
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| 1.981-3 |
Definitions and other special rules. |
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| 1.985-0 |
Outline of regulation. |
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| 1.985-1 |
Functional currency.
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| 1.985-2 |
Election to use the United States dollar as the functional currency of a QBU. |
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| 1.985-3 |
United States dollar approximate separate transactions method. |
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| 1.985-4 |
Method of accounting. |
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| 1.985-5 |
Adjustments required upon change in functional currency.
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| 1.985-6 |
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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| 1.985-7 |
Adjustments required in connection with a change to DASTM. |
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| 1.985-8 |
Special rules applicable to the European Monetary Union (conversion to euro). |
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| 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. |
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| 1.988-0 |
Taxation of gain or loss from a section 988 transaction; Table of Contents. |
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| 1.988-1
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Certain definitions and special rules. |
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| 1.988-2 |
Recognition and computation of exchange gain or loss. |
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| 1.988-3 |
Character of exchange gain or loss. |
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| 1.988-4 |
Source of gain or loss realized on a section 988 transaction. |
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| 1.988-5 |
Section 988(d) hedging transactions. |
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| 1.989(a)-1 |
Definition of a qualified business unit. |
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| 1.989(b)-1 |
Definition of weighted average exchange rate. |
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| 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. |
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| 1.991-1 |
Taxation of a domestic international sales corporation. |
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| 1.992-1 |
Requirements of a DISC. |
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| 1.992-2 |
Election to be treated as a DISC. |
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| 1.992-3 |
Deficiency distributions to meet qualification requirements. |
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| 1.992-4 |
Coordination with personal holding company provisions in case of certain produced film rents. |
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| 1.993-1 |
Definition of qualified export receipts. |
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| 1.993-2 |
Definition of qualified export assets. |
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| 1.993-3 |
Definition of export property. |
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| 1.993-4 |
Definition of producer's loans. |
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| 1.993-5 |
Definition of related foreign export corporation. |
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| 1.993-6 |
Definition of gross receipts. |
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| 1.993-7 |
Definition of United States. |
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| 1.994-1 |
Inter-company pricing rules for DISC's. |
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| 1.994-2 |
Marginal costing rules. |
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| 1.995-1 |
Taxation of DISC income to shareholders. |
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| 1.995-2 |
Deemed distributions in qualified years. |
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| 1.995-3 |
Distributions upon disqualification. |
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| 1.995-4 |
Gain on disposition of stock in a DISC. |
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| 1.995-5 |
Foreign investment attributable to producer's loans. |
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| 1.995-6 |
Taxable income attributable to military property. |
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| 1.996-1 |
Rules for actual distributions and certain deemed distributions. |
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| 1.996-2 |
Ordering rules for losses. |
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| 1.996-3 |
Divisions of earnings and profits. |
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| 1.996-4 |
Subsequent effect of previous disposition of DISC stock. |
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| 1.996-5 |
Adjustment to basis. |
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| 1.996-6 |
Effectively connected income. |
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| 1.996-7 |
Carryover of DISC tax attributes. |
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| 1.996-8 |
Effect of carryback of capital loss or net operating loss to prior DISC taxable year. |
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| 1.997-1 |
Special rules for subchapter C of the Code. |