Webeign corporations, Code §1248 can cause gain to be recharacterized as dividend income. In tax-free dispositions of shares of foreign corporations (such as in tax-free … Web§ 1248. Gain from certain sales or exchanges of stock in certain foreign corporations § 1249. Gain from certain sales or exchanges of patents, etc., to foreign corporations § 1250. Gain from dispositions of certain depreciable realty [§ 1251. Repealed. Pub. L. 98–369, div. A, title IV, § 492 (a), July 18, 1984, 98 Stat. 853] § 1252.

eCFR :: 26 CFR 1.1248-4 -- Limitation on tax applicable to individuals.

WebTo the extent related to subsection (a) of section 6048 of the Internal Revenue Code of 1986, as amended by this section, the amendments made by this section [amending this … WebUnder section 1248 (b), the limitation on the tax attributable to the $100 included by Smith in his gross income as a dividend under section 1248 (a) is $61.75, computed as follows: (i) Excess, computed under paragraph (c) of this section, of United States taxes which X Corporation would have paid in 1966 over the taxes actually paid by X in 1966. iron built fitness

Selling Partnerships That Own CFCs: A Potential Trap for

WebOne classic example highlighting the potential magnitude of a state versus federal income tax variance is an intercompany transaction that creates a gain for federal income tax purposes, yet is deferred under the federal consolidated return regulations. Webas section 951(a)(1)(A) inclusions for purposes of section 959. Sections 245A and 1248(j) generally allow a deduction with respect to gain on the sale of stock of a foreign corporation treated as a dividend under section 1248. In the case of gain treated as a dividend under section 964(e)(1) upon the sale or exchange by a CFC of stock of a WebI.R.C. § 1248 (b) (2) — an amount equal to the tax that would result by including in gross income, as gain from the sale or exchange of a capital asset held for more than 1 year, an … port noble wedge