26 C.F.R. § 1.1442-1
Withholding of tax on foreign corporations
For regulations concerning the withholding of tax at source under section 1442 in the case of foreign corporations, foreign governments, international organizations, foreign tax-exempt corporations, or foreign private foundations, see §§ 1.1441-1 through 1.1441-9.
Notes of Decisions
Cited in 3
cases, 1977–2016 · leading case: InverWorld v. Comm'r, 1996 T.C. Memo. 301 (Tax Ct. 1996).
InverWorld v. Comm'r, 1996 T.C. Memo. 301 (Tax Ct. 1996). “1442-1, Income Tax Regs. Sec. 1.1441-3(a), Income Tax Regs. b. Post-1986 Act Law (1) Character and Source Rules for Interest Generally, the source of *513 interest depends on the residence of the obligor.”
Vitco, Inc. v. Gov't of the Virgin Islands & Reuben Wheatley, Comm'r of Fin., 560 F.2d 180 (3rd Cir. 1977). “See 26 C.F.R. §§ 1.1442-1 , 1-1441-1. 7 This appeal is concerned only with the assessment against Vitco.”
Am. Metallurgical Coal Co. v. Comm'r, 2016 T.C. Memo. 139 (Tax Ct. 2016). “(applicable to interest payments made after December 31, 2000); sec. 1.1442-1 , Income Tax *171 Regs.”
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