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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

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]