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Title 26 Part 1

Title 26 → Chapter I → Subchapter A → Part 1

Electronic Code of Federal Regulations e-CFR

Title 26 Part 1

Title 26Chapter ISubchapter APart 1


TITLE 26—Internal Revenue

CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED)

SUBCHAPTER A—INCOME TAX (CONTINUED)

PART 1—INCOME TAXES (CONTINUED)

rule

Earned Income of Citizens or Residents of United States

§1.908
[Reserved]
§1.909-0
Outline of regulation provisions for section 909.
§1.909-1
Definitions and special rules.
§1.909-2
Splitter arrangements.
§1.909-3
Rules regarding related income and split taxes.
§1.909-4
Coordination rules.
§1.909-5
2011 and 2012 splitter arrangements.
§1.909-6
Pre-2011 foreign tax credit splitting events.
§1.910
[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.

earned income of citizens of united states

§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.
§1.927(a)-1T
Temporary regulations; definition of export property.
§1.927(b)-1T
[Reserved]
§1.927(d)-1
[Reserved]
§1.927(d)-2T
Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.

possessions of the united states

§1.931-1
Exclusion of certain income from sources within Guam, American Samoa, or the Northern Mariana Islands.
§1.932-1
Coordination of United States and Virgin Islands income taxes.
§1.933-1
Exclusion of certain income from sources within Puerto Rico.
§1.934-1
Limitation on reduction in income tax liability incurred to the Virgin Islands.
§1.935-1
Coordination of individual income taxes with Guam and the Northern Mariana Islands.
§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).
§1.936-8T
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.
§1.937-2
Income from sources within a possession.
§1.937-3
Income effectively connected with the conduct of a trade or business in a possession.

controlled foreign corporations

§1.951-1
Amounts included in gross income of United States shareholders.
§1.951-2
[Reserved]
§1.951-3
Coordination of subpart F with foreign personal holding company provisions.
§1.951A-0
Outline of section 951A regulations.
§1.951A-1
General provisions.
§1.951A-2
Tested income and tested loss.
§1.951A-3
Qualified business asset investment.
§1.951A-4
Tested interest expense and tested interest income.
§1.951A-5
Treatment of GILTI inclusion amounts.
§1.951A-6
Adjustments related to tested losses.
§1.951A-7
Applicability dates.
§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.
§1.954-3
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.
§1.954(c)(6)-1T
Certain cases in which section 954(c)(6) exception not available (temporary).
§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 the average of the amounts of United States property held by a controlled foreign corporation.
§1.956-1T
Shareholder's pro rata share of the average of the amounts of United States property held by a controlled foreign corporation (temporary).
§1.956-2
Definition of United States property.
§1.956-2T
Definition of United States Property (temporary).
§1.956-3
Certain trade or service receivables acquired from United States persons.
§1.956-4
Certain rules applicable to partnerships.
§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.
§1.958-1
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.
§1.963-0
Repeal of section 963; effective dates.
§1.963-1
[Reserved]
§1.963-2
Determination of the amount of the minimum distribution.
§1.963-3
Distributions counting toward a minimum distribution.
§1.963-4—1.963-5
[Reserved]
§1.963-6
Deficiency distribution.
§1.964-1
Determination of the earnings and profits of a foreign corporation.
§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.
§1.965-0
Outline of section 965 regulations.
§1.965-1
Overview, general rules, and definitions.
§1.965-2
Adjustments to earnings and profits and basis.
§1.965-3
Section 965(c) deductions.
§1.965-4
Disregard of certain transactions.
§1.965-5
Allowance of credit or deduction for foreign income taxes.
§1.965-6
Computation of foreign income taxes deemed paid and allocation and apportionment of deductions.
§1.965-7
Elections, payment, and other special rules.
§1.965-8
Affiliated groups (including consolidated groups).
§1.965-9
Applicability dates.

export trade corporations

§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).
§1.986(c)-1
Coordination with section 965.
§1.987-0
Section 987; table of contents.
§1.987-1
Scope, definitions, and special rules.
§1.987-1T
Scope, definitions, and special rules (temporary).
§1.987-2
Attribution of items to eligible QBUs; definition of a transfer and related rules.
§1.987-3
Determination of section 987 taxable income or loss of an owner of a section 987 QBU.
§1.987-3T
Determination of section 987 taxable income or loss of an owner of a section 987 QBU (temporary).
§1.987-4
Determination of net unrecognized section 987 gain or loss of a section 987 QBU.
§1.987-5
Recognition of section 987 gain or loss.
§1.987-6
Character and source of section 987 gain or loss.
§1.987-6T
Character and source of section 987 gain or loss (temporary).
§1.987-7
Section 987 aggregate partnerships.
§1.987-8
Termination of a section 987 QBU.
§1.987-8T
Termination of a section 987 QBU (temporary).
§1.987-9
Recordkeeping requirements.
§1.987-10
Transition rules.
§1.987-11
Effective/applicability date.
§1.987-12
Deferral of section 987 gain or loss.
§1.988-0
Taxation of gain or loss from a section 988 transaction; Table of Contents.
§1.988-1
Certain definitions and special rules.
§1.988-1T
Certain definitions and special rules (temporary).
§1.988-2
Recognition and computation of exchange gain or loss.
§1.988-2T
Recognition and computation of exchange gain or loss (temporary).
§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.

Domestic International Sales Corporations

§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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