Treasury Regulations (26 C.F.R.)
26 CFR § 1.904(b)-0
Outline of regulation provisions.
This section lists the headings for §§ 1.904(b)-1 and 1.904(b)-2.
(a) Capital gains and losses included in taxable income from sources outside the United States.
(1) Limitation on capital gain from sources outside the United States when the taxpayer has net capital losses from sources within the United States.
(i) In general.
(ii) Allocation of reduction to separate categories or rate groups.
(A) In general.
(B) Taxpayer with capital gain rate differential.
(2) Exclusivity of rules; no reduction by reason of net capital loss from sources outside the United States in a different separate category.
(3) Capital losses from sources outside the United States in the same separate category.
(4) Examples.
(b) Capital gain rate differential.
(1) Application of adjustments only if capital gain rate differential exists.
(2) Determination of whether capital gain rate differential exists.
(3) Special rule for certain noncorporate taxpayers.
(c) Rate differential adjustment of capital gains.
(1) Rate differential adjustment of capital gains in foreign source taxable income.
(i) In general.
(ii) Special rule for taxpayers with a net long-term capital loss from sources within the United States.
(iii) Examples.
(2) Rate differential adjustment of capital gains in entire taxable income.
(d) Rate differential adjustment of capital losses from sources outside the United States.
(1) In general.
(2) Determination of which capital gains are offset by net capital losses from sources outside the United States.
(e) Qualified dividend income.
(1) In general.
(2) Exception.
(f) Definitions.
(1) Alternative tax rate.
(2) Net capital gain.
(3) Rate differential portion.
(4) Rate group.
(i) Short-term capital gains or losses.
(ii) Long-term capital gains.
(iii) Long-term capital losses.
(5) Terms used in sections 1(h), 904(b) or 1222.
(g) Examples.
(h) Coordination with section 904(f).
(1) In general.
(2) Examples.
(i) Effective date.
(a) Application of section 904(b)(2)(B) adjustments.
(b) Use of alternative minimum tax rates.
(1) Taxpayers other than corporations.
(2) Corporate taxpayers.
(c) Effective date.
[T.D. 9371, 72 FR 72596, Dec. 21, 2007]
Source: view the official text
In this part (40 sections)
- 1.901(m)-2 · Covered asset acquisitions and relevant foreign assets.
- 1.901(m)-3 · Disqualified tax amount and aggregate basis difference…
- 1.901(m)-4 · Determination of basis difference.
- 1.901(m)-5 · Basis difference taken into account.
- 1.901(m)-6 · Successor rules.
- 1.901(m)-7 · De minimis rules.
- 1.901(m)-8 · Miscellaneous.
- 1.902-0 · Outline of regulations provisions for section 902.
- 1.902-1 · Credit for domestic corporate shareholder of a foreign…
- 1.902-2 · Treatment of deficits in post-1986 undistributed earnings and…
- 1.902-3 · Credit for domestic corporate shareholder of a foreign…
- 1.902-4 · Rules for distributions attributable to accumulated profits…
- 1.903-1 · Taxes in lieu of income taxes.
- 1.904-1 · Limitation on credit for foreign income taxes.
- 1.904-2 · Carryback and carryover of unused foreign tax.
- 1.904-3 · Carryback and carryover of unused foreign tax by spouses…
- 1.904-4 · Separate application of section 904 with respect to certain…
- 1.904-5 · Look-through rules as applied to controlled foreign…
- 1.904-6 · Allocation and apportionment of foreign income taxes.
- 1.904-7 · Transition rules.
- 1.904(b)-0 · Outline of regulation provisions.
- 1.904(b)-1 · Special rules for capital gains and losses.
- 1.904(b)-2 · Special rules for application of section 904(b) to…
- 1.904(b)-3 · Disregard of certain dividends and deductions under…
- 1.904(f)-0 · Outline of regulation provisions.
- 1.904(f)-1 · Overall foreign loss and the overall foreign loss account.
- 1.904(f)-2 · Recapture of overall foreign losses.
- 1.904(f)-3 · Allocation of net operating losses and net capital losses.
- 1.904(f)-4 · Recapture of foreign losses out of accumulation…
- 1.904(f)-5 · Special rules for recapture of overall foreign losses of a…
- 1.904(f)-6 · Transitional rule for recapture of FORI and general…
- 1.904(f)-7 · Separate limitation loss and the separate limitation loss…
- 1.904(f)-8 · Recapture of separate limitation loss accounts.
- 1.904(f)-9 - 1.904(f)-11 · §§ 1.904(f)-9-1.904(f)-11 [Reserved]
- 1.904(f)-12 · Transition rules.
- 1.904(g)-0 · Outline of regulation provisions.
- 1.904(g)-1 · Overall domestic loss and the overall domestic loss…
- 1.904(g)-2 · Recapture of overall domestic losses.
- 1.904(g)-3 · Ordering rules for the allocation of net operating losses,…
- 1.904(i)-0 · Outline of regulation provisions.