Treasury Regulations, Subchapter A, Part 1, Sections 1.851-1.907 - Index

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REGULATED INVESTMENT COMPANIES AND REAL ESTATE INVESTMENT TRUSTS

Sec. 1.851-1 Definition of regulated investment company

Sec. 1.851-2 Limitations

Sec. 1.851-3 Rules applicable to section 851(b)(4)

Sec. 1.851-4 Determination of status

Sec. 1.851-5 Examples

Sec. 1.851-6 Investment companies furnishing capital to development corporations

Sec. 1.851-7 Certain unit investment trusts

Sec. 1.852-1 Taxation of regulated investment companies

Sec. 1.852-2 Method of taxation of regulated investment companies

Sec. 1.852-3 Investment company taxable income

Sec. 1.852-4 Method of taxation of shareholders of regulated investment companies

Sec. 1.852-5 Earnings and profits of a regulated investment company

Sec. 1.852-6 Records to be kept for purpose of determining whether a corporation claiming to be a regulated investment company is a personal holding company

Sec. 1.852-7 Additional information required in returns of shareholders

Sec. 1.852-8 Information returns

Sec. 1.852-9 Special procedural requirements applicable to designation under section 852(b)(3)(D)

Sec. 1.852-10 Distributions in redemption of interests in unit investment trusts

Sec. 1.852-11 Treatment of certain losses attributable to periods after October 31 of a taxable year

Sec. 1.852-12 Non-RIC earnings and profits

Sec. 1.853-1 Foreign tax credit allowed to shareholders

Sec. 1.853-2 Effect of election

Sec. 1.853-3 Notice to shareholders

Sec. 1.853-4 Manner of making election

Sec. 1.854-1 Limitations applicable to dividends received from regulated investment company

Sec. 1.854-2 Notice to shareholders

Sec. 1.854-3 Definitions

Sec. 1.855-1 Dividends paid by regulated investment company after close of taxable year

Real Estate Investment Trusts

Sec. 1.856-0 Revenue Act of 1978 amendments not included

Sec. 1.856-1 Definition of real estate investment trust

Sec. 1.856-2 Limitations

Sec. 1.856-3 Definitions

Sec. 1.856-4 Rents from real property

Sec. 1.856-5 Interest

Sec. 1.856-6 Foreclosure property

Sec. 1.856-7 Certain corporations, etc., that are considered to meet the gross income requirements

Sec. 1.856-8 Revocation or termination of election

Sec. 1.856-9 Treatment of certain qualified REIT subsidiaries

Sec. 1.857-1 Taxation of real estate investment trusts

Sec. 1.857-2 Real estate investment trust taxable income and net capital gain

Sec. 1.857-3 Net income from foreclosure property

Sec. 1.857-4 Tax imposed by reason of the failure to meet certain source-of-income requirements

Sec. 1.857-5 Net income and loss from prohibited transactions

Sec. 1.857-6 Method of taxation of shareholders of real estate investment trusts

Sec. 1.857-7 Earnings and profits of a real estate investment trust

Sec. 1.857-8 Records to be kept by a real estate investment trust

Sec. 1.857-9 Information required in returns of shareholders

Sec. 1.857-10 Information returns

Sec. 1.857-11 Non-REIT earnings and profits

Sec. 1.858-1 Dividends paid by a real estate investment trust after close of taxable year

Sec. 1.860-1 Deficiency dividends

Sec. 1.860-2 Requirements for deficiency dividends

Sec. 1.860-3 Interest and additions to tax

Sec. 1.860-4 Claim for credit or refund

Sec. 1.860-5 Effective date

Sec. 1.860A-0 Outline of REMIC provisions

Sec. 1.860A-1 Effective dates and transition rules

Sec. 1.860C-1 Taxation of holders of residual interests

Sec. 1.860C-2 Determination of REMIC taxable income or net loss

Sec. 1.860D-1 Definition of a REMIC

Sec. 1.860E-1 Treatment of taxable income of a residual interest holder in excess of daily accruals

Sec. 1.860E-2 Tax on transfers of residual interests to certain organizations

Sec. 1.860F-1 Qualified liquidations

Sec. 1.860F-2 Transfers to a REMIC

Sec. 1.860F-4 REMIC reporting requirements and other administrative rules

Sec. 1.860G-1 Definition of regular and residual interests

Sec. 1.860G-2 Other rules

Sec. 1.860G-3 Treatment of foreign persons

TAX BASED ON INCOME FROM SOURCES WITHIN OR WITHOUT THE UNITED STATES

Determination of Sources of Income

Sec. 1.861-1 Income from sources within the United States

Sec. 1.861-2 Interest

Sec. 1.861-3 Dividends

Sec. 1.861-3T Dividends (temporary)

Sec. 1.861-4 Compensation for labor or personal services

Sec. 1.861-5 Rentals and royalties

Sec. 1.861-6 Sale of real property

Sec. 1.861-7 Sale of personal property

Sec. 1.861-8 Computation of taxable income from sources within the United States and from other sources and activities

Sec. 1.861-8T Computation of taxable income from sources within the United States and from other sources and activities (temporary)

Sec. 1.861-9 Allocation and apportionment of interest expense

Sec. 1.861-9T Allocation and apportionment of interest expense (temporary)

Sec. 1.861-10 Special allocations of interest expense

Sec. 1.861-10T Special allocations of interest expense (temporary regulations)

Sec. 1.861-11 Special rules for allocating and apportioning interest expense of an affiliated group of corporations

Sec. 1.861-11T Special rules for allocating and apportioning interest expense of an affiliated group of corporations (temporary regulations.)

Sec. 1.861-12T Characterization rules and adjustments for certain assets (temporary regulations.)

Sec. 1.861-13T Transition rules for interest expenses (temporary regulations)

Sec. 1.861-14 Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations

Sec. 1.861-14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary)

Sec. 1.861-15 Income from certain aircraft or vessels first leased on or before December 28, 1980

Sec. 1.861-16 Income from certain craft first leased after December 28, 1980

Sec. 1.861-17 Allocation and apportionment of research and experimental expenditures

Sec. 1.861-18 Classification of transactions involving computer programs

Sec. 1.862-1 Income specifically from sources without the United States

Sec. 1.863-0 Table of contents

Sec. 1.863-1 Allocation of gross income under section 863(a)

Sec. 1.863-2 Allocation and apportionment of taxable income

Sec. 1.863-3 Allocation and apportionment of income from certain sales of inventory

regulations applicable to taxable years prior to december 30, 1996

Sec. 1.863-3A Income from the sale of personal property derived partly from within and partly from without the United States

Sec. 1.863-3AT Income from the sale of personal property derived partly from within and partly from without the United States (temporary regulations)

Sec. 1.863-4 Certain transportation services

Sec. 1.863-6 Income from sources within a foreign country

Sec. 1.863-7 Allocation of income attributable to certain notional principal contracts under section 863(a)

Sec. 1.864-1 Meaning of sale, etc

Sec. 1.864-2 Trade or business within the United States

Sec. 1.864-3 Rules for determining income effectively connected with U.S. business of nonresident aliens or foreign corporations

Sec. 1.864-4 U.S. source income effectively connected with U.S. business

Sec. 1.864-5 Foreign source income effectively connected with U.S. business

Sec. 1.864-6 Income, gain, or loss attributable to an office or other fixed place of business in the United States

Sec. 1.864-7 Definition of office or other fixed place of business

Sec. 1.864-8T Treatment of related person factoring income (temporary)

Sec. 1.865-1 Loss with respect to personal property other than stock

Sec. 1.865-2 Loss with respect to stock

Nonresident Aliens and Foreign Corporations

nonresident alien individuals

Sec. 1.871-1 Classification and manner of taxing alien individuals

Sec. 1.871-2 Determining residence of alien individuals

Sec. 1.871-3 Residence of alien seamen

Sec. 1.871-4 Proof of residence of aliens

Sec. 1.871-5 Loss of residence by an alien

Sec. 1.871-6 Duty of witholding agent to determine status of alien payees

Sec. 1.871-7 Taxation of nonresident alien individuals not engaged in U.S. business

Sec. 1.871-8 Taxation of nonresident alien individuals engaged in U.S. business or treated as having effectively connected income

Sec. 1.871-9 Nonresident alien students or trainees deemed to be engaged in U.S. business

Sec. 1.871-10 Election to treat real property income as effectively connected with U.S. business

Sec. 1.871-11 Gains from sale or exchange of patents, copyrights, or similar property

Sec. 1.871-12 Determination of tax on treaty income

Sec. 1.871-13 Taxation of individuals for taxable year of change of U.S. citizenship or residence

Sec. 1.871-14 Rules relating to repeal of tax on interest of nonresident alien individuals and foreign corporations received from certain portfolio debt investments

Sec. 1.872-1 Gross income of nonresident alien individuals

Sec. 1.872-2 Exclusions from gross income of nonresident alien individuals

Sec. 1.873-1 Deductions allowed nonresident alien individuals

Sec. 1.874-1 Allowance of deductions and credits to nonresident alien individuals

Sec. 1.875-1 Partnerships

Sec. 1.875-2 Beneficiaries of estates or trusts

Sec. 1.876-1 Alien residents of Puerto Rico, Guam, American Samoa, or the Northern Mariana Islands

Sec. 1.876-1T Alien residents of Puerto Rico, Guam, American Samoa, or the Northern Mariana Islands (temporary)

Sec. 1.879-1 Treatment of community income

foreign corporations

Sec. 1.881-0 Table of contents

Sec. 1.881-1 Manner of taxing foreign corporations

Sec. 1.881-2 Taxation of foreign corporations not engaged in U.S. business

Sec. 1.881-3 Conduit financing arrangements

Sec. 1.881-4 Recordkeeping requirements concerning conduit financing arrangements

Sec. 1.881-5T Exception for certain possessions corporations (temporary)

Sec. 1.882-0 Table of contents

Sec. 1.882-1 Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected income

Sec. 1.882-2 Income of foreign corporations treated as effectively connected with U.S. business

Sec. 1.882-3 Gross income of a foreign corporation

Sec. 1.882-4 Allowance of deductions and credits to foreign corporations

Sec. 1.882-5 Determination of interest deduction

Sec. 1.883-0 Outline of major topics

Sec. 1.883-1 Exclusion of income from the international operation of ships or aircraft

Sec. 1.883-2 Treatment of publicly-traded corporations

Sec. 1.883-3 Treatment of controlled foreign corporations

Sec. 1.883-4 Qualified shareholder stock ownership test

Sec. 1.883-5 Effective dates

Sec. 1.884-0 Overview of regulation provisions for section 884

Sec. 1.884-0T Overview of regulation provisions for section 884 (temporary)

Sec. 1.884-1 Branch profits tax

Sec. 1.884-2 Special rules for termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary

Sec. 1.884-2T Special rules for termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary (temporary)

Sec. 1.884-3T Coordination of branch profits tax with second-tier withholding (temporary). (Reserved)

Sec. 1.884-4 Branch-level interest tax

Sec. 1.884-5 Qualified resident

miscellaneous provisions

Sec. 1.891 Statutory provisions; doubling of rates of tax on citizens and corporations of certain foreign countries

Sec. 1.892-1T Purpose and scope of regulations (temporary regulations)

Sec. 1.892-2T Foreign government defined (temporary regulations)

Sec. 1.892-3T Income of foreign governments (temporary regulations)

Sec. 1.892-4T Commercial activities (temporary regulations)

Sec. 1.892-5 Controlled commercial entity

Sec. 1.892-5T Controlled commercial entity (temporary regulations)

Sec. 1.892-6T Income of international organizations (temporary regulations)

Sec. 1.892-7T Relationship to other Internal Revenue Code sections (temporary regulations)

Sec. 1.893-1 Compensation of employees of foreign governments or international organizations

Sec. 1.894-1 Income affected by treaty

Sec. 1.895-1 Income derived by a foreign central bank of issue, or by Bank for International Settlements, from obligations of the United States or from bank deposits

Sec. 1.897-1 Taxation of foreign investment in United States real property interests, definition of terms

Sec. 1.897-2 United States real property holding corporations

Sec. 1.897-3 Election by foreign corporation to be treated as a domestic corporation under section 897(i)

Sec. 1.897-4AT Table of contents (temporary)

Sec. 1.897-5 Corporate distributions

Sec. 1.897-5T Corporate distributions (temporary)

Sec. 1.897-6T Nonrecognition exchanges applicable to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganizations (temporary)

Sec. 1.897-7T Treatment of certain partnership interests as entirely U.S. real property interests under sections 897(g) and 1445(e) (temporary)

Sec. 1.897-8T Status as a U.S. real property holding corporation as a condition for electing section 897(i) pursuant to Sec. .897 - 3 (temporary)

Sec. 1.897-9T Treatment of certain interest in publicly traded corporations, definition of foreign person, and foreign governments and international organizations (temporary)

Income From Sources Without the United States

foreign tax credit

Sec. 1.901-1 Allowance of credit for taxes

Sec. 1.901-1T Allowance of credit for taxes (temporary)

Sec. 1.901-2 Income, war profits, or excess profits tax paid or accrued

Sec. 1.901-2A Dual capacity taxpayers

Sec. 1.901-3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit

Sec. 1.902-0 Outline of regulations provisions for section 902

Sec. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation

Sec. 1.902-2 Treatment of deficits in post-1986 undistributed earnings and pre-1987 accumulated profits of a first-, second-, or third-tier corporation for purposes of computing an amount of foreign taxes deemed paid under Sec. .902 - 1

Sec. 1.902-3 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before January 1, 1987

Sec. 1.902-4 Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation

Sec. 1.903-1 Taxes in lieu of income taxes

Sec. 1.904-0 Outline of regulation provisions for section 904

Sec. 1.904-1 Limitation on credit for foreign taxes

Sec. 1.904-2 Carryback and carryover of unused foreign tax

Sec. 1.904-3 Carryback and carryover of unused foreign tax by husband and wife

Sec. 1.904-4 Separate application of section 904 with respect to certain categories of income

Sec. 1.904-5 Look-through rules as applied to controlled foreign corporations and other entities

Sec. 1.904-6 Allocation and apportionment of taxes

Sec. 1.904-7 Transition rules

Sec. 1.904(b)-1 Special rules for capital gains and losses

Sec. 1.904(b)-2 Special rules for application of section 904(b) to alternative minimum tax foreign tax credit

Sec. 1.904(f)-1 Overall foreign loss and the overall foreign loss account

Sec. 1.904(f)-2 Recapture of overall foreign losses

Sec. 1.904(f)-3 Allocation of net operating losses and net capital losses

Sec. 1.904(f)-4 Recapture of foreign losses out of accumulation distributions from a foreign trust

Sec. 1.904(f)-5 Special rules for recapture of overall foreign losses of a domestic trust

Sec. 1.904(f)-6 Transitional rule for recapture of FORI and general limitation overall foreign losses incurred in taxable years beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982

Sec. 1.904(f)-7--1.904(f)-11 (Reserved)

Sec. 1.904(f)-12 Transition rules

Sec. 1.904(i)-1 Limitation on use of deconsolidation to avoid foreign tax credit limitations

Sec. 1.904(j)-1 Certain individuals exempt from foreign tax credit limitation

Sec. 1.905-1 When credit for taxes may be taken

Sec. 1.905-2 Conditions of allowance of credit

Sec. 1.905-3T Adjustments to the pools of foreign taxes and earnings and profits when the allowable foreign tax credit changes (temporary)

Sec. 1.905-4T Notification and redetermination of United States tax liability (temporary)

Sec. 1.905-5T Foreign tax redeterminations and currency translation rules for foreign tax redeterminations occurring in taxable years beginning prior to January 1, 1987 (temporary)

Sec. 1.907-0 Outline of regulation provisions for section 907

Sec. 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982)

Sec. 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982)

Sec. 1.907(b)-1 Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982)

Sec. 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982)

Sec. 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982)

Sec. 1.907(c)-3 FOGEI and FORI taxes (for taxable years beginning after December 31, 1982)

Sec. 1.907(d)-1 Disregard of posted prices for purposes of chapter 1 of the Code (for taxable years beginning after December 31, 1982)

Sec. 1.907(e)-1 (Reserved)

Sec. 1.907(f)-1 Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982)