Page:United States Statutes at Large Volume 68A.djvu/322

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INTERNAL REVENUE CODE OF 1954

SEC. 877. FOREIGN EDUCATIONAL, CHARITABLE, AND CERTAIN OTHER EXEMPT ORGANIZATIONS. For special provisions relating to unrelated business income of foreign educational, charitable, and other exempt trusts, see section 512 (a).

Subpart B—Foreign Corporations Sec. 881. Tax on foreign corporations not engaged in business in United States. Sec. 882. Tax on resident foreign corporations. Sec. 883. Exclusions from gross income. Sec. 884. Cross references. SEC. 881. TAX ON FOREIGN CORPORATIONS NOT ENGAGED IN BUSINESS IN UNITED STATES. (a) IMPOSITION OF T A X. — I n the case of every foreign corporation

not engaged in trade or business within the United States, there is hereby imposed for each taxable year, in lieu of the taxes imposed by section 11, a tax of 30 percent of the amount received from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income (including amounts described in section 631(b) and (c) which are considered to be gains from the sale or exchange of capital assets). (b) DOUBLING OF T A X. —

For doubling of tax on corporations of certain foreign countries, see section 891. SEC. 882. TAX ON RESIDENT FOREIGN CORPORATIONS. (a) IMPOSITION OF T A X. — A foreign corporation engaged in trade or business within the United States shall be taxable as provided in section 11. (b) GEOSS INCOME.—In the case of a foreign corporation, gross income includes only the gross income from sources within the United States. • (c) ALLOWANCE OF DEDUCTIONS AND C R E D I T S. — (1) DEDUCTIONS ALLOWED ONLY I F RETURN FILED.—A foreign

corporation shall receive the benefit of the deductions allowed to it in this subtitle only by filing or causing to be filed with the Secretary or his delegate a true and accurate return of its total income received from all sources in the United States, in the manner prescribed in subtitle F, including therein all the information which the Secretary or his delegate may deem necessary for the calculation of such deductions. (2) ALLOCATION OF DEDUCTIONS.—In the case of a foreign corporation the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States; and the proper apportionment and allocation of the deductions with respect to sources within and without the United States shall be determined as provided in part I, under regulations prescribed by the Secretary or his delegate. (3) CHARITABLE CONTRIBUTIONS.—The deduction for charitable contributions and gifts provided by section 170 shall be allowed whether or not connected with income from sources within the United States. §877 &,._.^:,|--,-„.-,;.;,t.

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