Sec.

1.871-4

Proof of residence of aliens.

1.871-5 Loss of residence by an alien.

1.871-6 Duty of employer to determine status of alien employee.

1.871-7 Tax on nonresident alien individuals.

1.871-8 Definition of engaging in trade or business within the United States. 1.872 Statutory provisions; gross income.

1.872-1 Gross income of nonresident alien individuals.

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

1.873 Statutory provisions; deductions.

1.873-1 Deductions allowed nonresident alien individuals.

1.874 Statutory provisions; allowance of deductions and credits.

1.874-1 Allowances of deductions and credits to nonresident alien individuals. 1.875 Statutory provisions; partnerships.

1.875-1

Partnerships.

1.876 Statutory provisions; alien residents of Puerto Rico.

1.876-1 Alien residents of Puerto Rico.

1.877 Statutory provisions; certain foreign exempt organizations.

FOREIGN CORPORATIONS

1.881 Statutory provisions; tax on foreign corporations not engaged in business in the United States.

1.881-1 Taxation of foreign corporations.

1.881-2 Tax on nonresident foreign corporations.

1.882 Statutory provisions; tax on resident foreign corporations. 1.882-1 Tax on resident foreign corporations.

1.882-2 Gross income of foreign corporations.

1.882-3

Deductions allowed foreign corporations.

1.882-4 Allowance of deductions to foreign corporations.

1.883 Statutory provisions; exclusions from gross income.

1.883-1 Exclusions from gross income of foreign corporations. 1.884 Statutory provisions; cross references.

1.891

MISCELLANEOUS PROVISIONS

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

1.892 Statutory provisions; income of foreign governments and of international organizations.

1.892-1 Income of foreign governments and international organizations.

1.893 Statutory provisions; compensation of employees of foreign governments or international organizations.

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

1.894 Statutory provisions; income exempt under treaty.

1.894-1 Income exempt under treaty.

1.895 Statutory provisions; income derived by a foreign central bank of issue from obligations of the United States.

1.895-1 Income derived by a foreign central bank of issue from obligations of the United States.

INCOME FROM SOURCES WITHOUT THE UNITED STATES

FOREIGN TAX CREDIT

1.901 Statutory provisions; taxes of foreign countries and of possessions of the United States.

1.902 Statutory provisions; credit for corporate stockholder in foreign corporation. 1.902-1 Credit for domestic corporate shareholder of a foreign corporation (before amendment by Revenue Act of 1962).

1.902-2 Special rules for payments from certain wholly-owned foreign corporations (before amendment by Revenue Act of 1962).

1.902-3 Credit for domestic corporate shareholder of a foreign corporation (after amendment by Revenue Act of 1962).

1.902-4 Definition of less developed country corporation for purposes of section 902.

Sec.

1.902-5 Effective dates for the application of section 902 (as amended by Revenue Act of 1962).

1.903 Statutory provisions; credit for taxes in lieu of income, etc., taxes.

1.903-1 Definition of taxes in lieu of income, war profits, or excess profits taxes. 1.904 Statutory provisions; limitation on credit.

1.904-1 Limitation on credit for foreign taxes.

1.904-2

Carryback and carryover of unused foreign tax.

1904-3 Carryback and carryover of unused foreign tax by husband and wife.

1.905 Statutory provisions; applicable rules.

1.905-1 When credit for taxes may be taken.

1.905-2 1.905-3

Conditions of allowance of credit.

Redetermination of the tax when credit proves incorrect. 1.905-4 Credit for taxes accrued but not paid.

1.905-5 Credit for United Kingdom income taxes paid with respect to royalties. EARNED INCOME OF CITIZENS OF UNITED STATES

1.911 Statutory provisions; earned income from sources without the United States. 1.911-1 Earned income from sources without the United States attributable to services performed before 1963.

1.911-2 Earned income from sources without the United States attributable to services performed after 1962.

1.912 Statutory provisions; exemption for certain allowances.

1.912-1 Exclusion of certain cost-of-living allowances.

1.912-2 Exclusion of certain allowances of Foreign Service personnel.

1.921

WESTERN HEMISPHERE TRADE CORPORATIONS

Statutory provisions; definition of Western Hemisphere trade corporations. 1.921-1 Definition of Western Hemisphere trade corporation.

1.922 Statutory provisions; special deduction.

1.922-1 Special deduction of Western Hemisphere trade corporation.

POSSESSIONS OF THE UNITED STATES

1.931 Statutory provisions; income from sources within possessions of the United States.

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 Statutory provisions; taxation of citizens of possessions of the United States. 1.932-1 Status of citizens of United States possessions.

1.933 Statutory provisions; income from sources within Puerto Rico.

1.933-1 Exclusion of certain income from sources within Puerto Rico.

1.934 Statutory provisions; limitation on reduction in income tax liability incurred to the Virgin Islands.

1.934-1 Limitation on reduction in income tax liability incurred to the Virgin

Islands.

CHINA TRADE ACT CORPORATIONS

1.941 Statutory provisions; special deduction for China Trade Act corporations. 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.

1.942

Statutory provisions; disallowance of foreign tax credit.

Kong.

1.943 Statutory provisions; exclusion of dividends to residents of Formosa or Hong 1.943-1 Withholding by a China Trade Act corporation.

CONTROLLED FOREIGN CORPORATIONS

1.951 Statutory provisions; amounts included in gross income of United States shareholders.

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 pro

visions.

1.952 Statutory provisions; subpart F income defined. 1.952-1 Subpart F income defined.

Sec.

1.952-2 Determination of gross income and taxable income of a foreign corporation.

1.953 Statutory provisions; income from insurance of United States risks. 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 Statutory provisions; foreign base company income.

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.

1.955 Statutory provisions; withdrawal of previously excluded subpart F income from qualified investment.

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.

1.956 Statutory provisions; investment of earnings in United States property. 1.956-1 Shareholders pro rata share of a controlled foreign corporation's increase in earnings invested in United States property.

1.956-2 Definition of United States property.

1.957 Statutory provisions; controlled foreign corporations; United States persons. 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 Statutory provisions; rules for determining stock ownership.

1.958-1 Direct and indirect ownership of stock.

1.958-2 Constructive ownership of stock.

1.959 Statutory provisions; exclusion from gross income of previously taxed earnings and profits.

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.

1.961 Statutory provisions; adjustments to basis of stock in controlled foreign corporations and of other property.

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 Statutory provisions; election by individuals to be subject to tax at corporate

rates.

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.

1.963 Statutory provisions; receipt of minimum distributions by domestic corporations.

1.963-1 Exclusion of subpart F income upon receipt of minimum distribution. 1.963-2 Determination of the amount of the minimum distribution. Distributions counting toward a minimum distribution. 1.963-4 Limitations on minimum distribution from a chain or group.

1.963-3

Sec.

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.

1.964 Statutory provisions; miscellaneous provisions.

Determination of the earnings and profits of a foreign corporation.
Treatment of blocked earnings and profits.

1.964-1

1.964-2

1.964-3 1.964-4

Records to be provided by United States shareholders.

Verification of certain classes of income.

EXPORT TRADE CORPORATIONS

1.970 Statutory provisions; reduction of subpart F income of export trade corporations.

1.970-1

1.970-2

Export trade corporations.

Elections as to date of determining investments in export trade assets.

1.970-3 Effective date of subpart G.

1.971 Statutory provisions; definitions.

1.971-1 Definitions with respect to export trade corporations.

1.972 Statutory provisions; consolidation of group of export trade corporations. 1.972-1 Consolidation of group of export trade corporations.

1.1001

GAIN OR LOSS ON DISPOSITION OF PROPERTY

DETERMINATION OF AMOUNT OF AND RECOGNITION OF GAIN OR Loss

Statutory provisions; determination of amount of and recognition of gain or loss.

1.1001-1 Computation of gain or loss.

1.1002 Statutory provisions; recognition of gain or loss.

1.1002-1 Sales or exchanges.

BASIS RULES OF GENERAL APPLICATION

1.1011 Statutory provisions; adjusted basis for determining gain or loss. 1.1011-1 Adjusted basis.

1.1012 Statutory provisions; basis of property-cost.

1.1012-1 Basis of property.

1.1012-2

1.1013

Transfers in part a sale and in part a gift.

Statutory provisions; basis of property included in inventory.

1.1013-1 Property included in inventory.

1.1014 Statutory provisions; basis of property acquired from a decedent. 1.1014-1 Basis of property acquired from a decedent.

1.1014-6

Gain or loss.

Special rule for adjustments to basis where property is acquired from a decedent prior to his death.

1.1014-7 Example applying rules of §§ 1.1014–4 through 1.1014–6 to case involving multiple interests.

1.1014-8 Bequest, devise, or inheritance of a remainder interest.

1.1015 Statutory provisions; basis of property acquired by gifts and transfers in trust.

1.1015-1 Basis of property acquired by gift after December 31, 1920.

1.1015-2

Transfer of property in trust after December 31, 1920.

Transfers in part a gift and in part a sale.

1.1015-3 Gift or transfer in trust before January 1, 1921.

1.1015-4

1.1016-3 Exhaustion, wear and tear, obsolescence, amortization, and depletion for periods since February 28, 1913.

1.1016-4 Exhaustion, wear and tear, obsolescence, amortization, and depletion; periods during which income was not subject to tax.

1.1016-7 Adjusted basis; cancellation of indebtedness under Bankruptcy Act.

Sec.

1.1016-8 Adjusted basis; cancellation of indebtedness; special cases.

1.1016-9 Adjusted basis; mutual savings banks, building and loan associations, and cooperative banks.

1.1016-10 Substituted basis.

1.1017 Statutory provisions; discharge of indebtedness.

1.1017-1 Adjusted basis; discharge of indebtedness; general rule.

1.1017-2 Adjusted basis; discharge of indebtedness; special cases.

1.1018 Statutory provisions; adjustment of capital structure before September 22, 1938.

1.1018-1 Adjusted basis; exception to section 270 of the Bankruptcy Act, as

amended.

1.1019 Statutory provisions; property on which lessee has made improvements. 1.1019-1 Property on which lessee has made improvements.

1.1020 Statutory provisions; election in respect of depreciation, etc., allowed before 1952.

1.1020-1 Election as to amounts allowed in respect of depreciation, etc., before 1952. 1.1021 Statutory provisions; sale of annuities.

1.1021-1 Sale of annuities.

1.1022 Statutory provisions; cross references.

COMMON NONTAXABLE EXCHANGES

1.1031(a) Statutory provisions; exchange of property held for productive use or investment; nonrecognition of gain or loss from exchanges solely in kind. 1.1031(a)-1 Property held for productive use in trade or business or for investment. 1.1031(b) Statutory provisions; exchange of property held for productive use or investment; gain from exchanges not solely in kind.

1.1031(b)-1 Receipt of other property or money in tax-free exchange.

1.1031(c) Statutory provisions; exchange of property held for productive use or investment; loss from exchanges not solely in kind.

1.1031(c)-1 Nonrecognition of loss.

1.1031(d) Statutory provisions; exchange of property held for productive use or investment; basis.

1.1031(d)-1 Property acquired upon a tax-free exchange.

1.1031(d)-2 Treatment of assumption of liabilities.

1.1032 Statutory provisions; exchange of stock for property.

1.1032-1 Disposition by a corporation of its own capital stock.

1.1033(a) Statutory provisions; involuntary conversions; general rule.

1.1033(a)-1 Involuntary conversions; nonrecognition of gain.

1.1033 (a)-2 Involuntary conversion where disposition of the converted property occurred after December 31, 1950.

1.1033(a)-3 Involuntary conversion where disposition of the converted property occurred before January 1, 1951.

1.1033 (a)-4 Replacement funds where disposition of the converted property occurred before January 1, 1951.

1.1033 (b) Statutory provisions; involuntary conversions; residence of taxpayer. 1.1033 (b) -1 Involuntary conversion of principal residence.

1.1033 (c) Statutory provisions; involuntary conversions; basis of property acquired through involuntary conversion.

1.1033 (c)-1 Basis of property acquired as a result of an involuntary conversion. 1.1033 (d) Statutory provisions; involuntary conversions; property sold pursuant to reclamation laws.

1.1033 (d)-1 Disposition of excess property within irrigation project deemed to be involuntary conversion.

1.1033(e) Statutory provisions; involuntary conversions; livestock destroyed by disease.

1.1033 (e)-1 Destruction or disposition of livestock because of disease. 1.1033 (f) Statutory provisions; livestock sold on account of drought. 1.1033 (f)-1 Sale or exchange of livestock solely on account of drought. 1.1033(g) Statutory provisions; involuntary conversions; condemnation of real property held for productive use in trade or business or for investment. 1.1033 (g)-1 Condemnation of real property held for productive use in trade or business or for investment.

1.1033 (h)

Statutory provisions; involuntary conversions; cross references. 1.1033 (h)-1 Effective date.

1.1034 Statutory provisions; sale or exchange of residence.