2004 CFR Title 26, Volume 10

Title 26--Internal Revenue CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1--INCOME TAXES
	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	Citizens of the United States and domestic corporations deriving income from sources within a certain possession of the United States.
	1.932-1	Status of citizens of U.S. possessions.
	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 U.S. and Guam individual income taxes.
	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).
	1.936-10	Qualified investments.
	1.936-11	New lines of business prohibited.
	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.
	1.954-3	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	Corporations organized in United States possessions.
	1.957-4	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.
	1.962-4	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	Special rules for computing earnings and profits of controlled foreign corporations in taxable years beginning after December 31, 1986 (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).
	1.987-5	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.
	1.989(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.