(a) General ruleFor purposes of this subtitle, the term "personal holding company" means any corporation (other than a corporation described in subsection (c)) if— (1) Adjusted ordinary gross income requirementAt least 60 percent of its adjusted ordinary gross income (as defined in

section 852(b)(7), amounts to which subsection (a) is applicable shall be treated as received by the shareholder in the taxable year in which the distribution is made. (c) Foreign tax electionIf an investment company to which section 853 is applicable for the taxable year makes a

for the taxable year shall be treated as a deduction allocable to such activity in the first succeeding taxable year. (3) Special rules for applying paragraph (1)(B)For purposes of paragraph (1)(B)— (A) section 544(a)(2) shall be applied as if such section did not contain the phrase "or by or for his partner"; and

(a) Reduction in amount allowed as foreign tax under section 901In applying section 901, the amount of any foreign oil and gas taxes paid or accrued (or deemed to have been paid) during the taxable year which would (but for this subsection

(a) General ruleIf— (1) a partnership has effectively connected taxable income for any taxable year, and (2) any portion of such income is allocable under section 704 to a foreign partner, such partnership shall pay a withholding

applies. (C) Section 1277 not applicable to tax-exempt obligationsFor purposes of section 1277, the term "market discount bond" shall not include any tax-exempt obligation (as defined in

corporation or domestic partnership, if such branch is engaged in the commercial banking business, (3) debt obligations, if, without regard to whether a statement meeting the requirements of section 871(h)(5) has been received, any interest thereon would be eligible for the exemption from tax under

(a) Computation of gain or lossThe gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided in such section for determining loss over the amount realized

(a) Allowance of creditA nonresident alien individual or a foreign corporation engaged in trade or business within the United States during the taxable year shall be allowed a credit under section 901 for the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or

another plan, the plan administrator (within the meaning of section 414(g)) shall file an actuarial statement of valuation evidencing compliance with the requirements of section 401(a)(12). (c) EmployerFor purposes of this section, the term "employer" includes a

purpose and duration of the visit and the size of the party and areas to be visited are other considerations which may affect the commander's decision whether to permit visiting by members of the public. (b) Any person or group desiring to enter a particular naval installation or portion thereof, shall submit a written request to the commander of the installation well enough in advance to allow a reasonable time for reply by mail. Mailing addresses for commanders of

. Requests for entry authorization to any other facility or property shall be addressed to the following: Commander, U.S. Naval Forces, Caribbean, Box 3037, Ceiba, PR 00635. (c) Each request for entry will be considered on an individual basis and consent will be determined by applicable installation entry instructions. Factors that will be considered include the purpose of visit, the size of party, duration of visit, destination

At Entrance Fee Areas: (a) Special admission permits for uses, such as group activities, may be issued. (b) No entrance fee shall be charged for persons under 16 years of age. (c) No entrance fee shall be charged for travel by private noncommercial vehicle over any road or highway established as part of the National Federal Aid System (defined in

other qualified real estate investment trusts. The term “mortgages on real property” includes deeds of trust on real property. (2) Treatment of REMIC interests as real estate assets—(i) In general. If, for any calendar quarter, at least 95 percent of a REMIC's assets (as determined in accordance with

(a) In general. Except as provided in paragraphs (b), (c), (d), and (e) of this section, the provisions of §§1.179-1 through 1.179-5 apply for property placed in service by the taxpayer in taxable years ending after January 25, 1993. However, a taxpayer may apply the provisions of

(a) General. (1) Tolerances for residues of the insecticide 2,2-dichlorovinyl dimethyl phosphate are established as follows: Open Table

(a) General ruleFor purposes of this part, the items of tax preference determined under this section are— (1) DepletionWith respect to each property (as defined in section 614), the excess of the deduction for depletion allowable under

made. (c) DefinitionsFor purposes of this section (1) Appropriate Federal officialThe term "appropriate Federal official" means— (A) the Commissioner of Social Security in the case of social security benefits described in section 86(d)(1)(A), and

from whom he collected it, or obtains the consent of such person to the allowance of such credit or refund. (b) Credit on returnsAny person entitled to a refund of tax imposed by section 4251, 4261, or 4271 paid, or collected and paid, to the Secretary by him may, instead of filing a claim for refund, take credit therefor against taxes imposed by such