 | 1941 - 1688 páginas
...proportion of any Income, war-profits, and excess-profits taxes paid or accrued by such controlled foreign corporation to any foreign country or to any...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. The amount of taxes deemed... | |
 | United States. Board of Tax Appeals - 1939 - 1380 páginas
...proportion of any income * * * taxes paid by such foreign corporation to auy foreign country * * * upon or with respect to the accumulated profits of...dividends bears to the amount of such accumulated profits • * *. Note that (f) allows no credit but merely provides that the domestic parent shall be deemed... | |
 | United States. Board of Tax Appeals - 1941 - 1630 páginas
...be deemed to have paid the same proportion of any income, war-profits, or excess-profits taxes paid by such foreign corporation to any foreign country...corporation from which such dividends were paid, which the amonnt of inch dividends bears to the amonnt of such accumulated profits : J'roi'iifd, That the amount... | |
 | United States - 1953 - 1744 páginas
...have paid the same proportion of any income, war-profits, or excess-profits taxes paid by such other foreign corporation to any foreign country or to any...upon or with respect to the accumulated profits of the corporation from which such dividends were paid, which the amount of such dividends bears to the... | |
 | United States - 1964 - 1098 páginas
...In subsection (c)(l)(B)) of such other foreign corporation from which such dividends were paid" for "from which such dividends were paid, which the amount...bears to the amount of such accumulated profits." Subsec. (c). Pub. L. 87-834 defined "accumulated profits" for purposes of subsec. (a)(l) and (b)(l)... | |
 | United States. Tax Court - 1944 - 1686 páginas
...be deemed to have paid the same proportion of any Income, war-profits, or excess-profits taxes paid by such foreign corporation to any foreign country...of the United States, upon or with respect to the treumolated profits of such foreign corporation from which snch dividends were paid which tbe amount... | |
 | 1944 - 1344 páginas
...paid the same proportion of any income, war-profits, or excess-profits taxes paid or deemed to be paid by such foreign corporation to any foreign country...profits of such foreign corporation from which such dividend? were paid, which the amount of such dividends bears to the amount of such accumulated profits."... | |
 | United States, Walter Elbert Barton - 1944 - 1286 páginas
...have paid the same proportion of any income, warprofits, or excess-profits taxes paid by such other foreign corporation to any foreign country or to any...upon or with respect to the accumulated profits of the corporation from which such dividends were paid, which the amount of such dividends bears to the... | |
 | Philippines - 1945 - 1064 páginas
...income, war-profits, or excess-profits taxes paid by such foreign corporation to any foreign country, upon or with respect to the accumulated profits of...shall in no case exceed the same proportion of the tax against which credit is taken which the amount of such dividends bears to the amount of the entire... | |
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... paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends... 
