extent provided in regulations, such term does not include any income of a kind to which an exemption under paragraph (1) or (2) of section 883(a) would not apply. (2) Exception for certain income effectively connected with business in the United StatesThe term "United States source gross transportation income" shall not include any income taxable under

Any individual who in any calendar year makes any transfer by gift other than— (1) a transfer which under subsection (b) or (e) of section 2503 is not to be included in the total amount of gifts for such year, (2) a transfer of an interest with respect to which a deduction is allowed under

Where tobacco products, or cigarette papers or tubes are removed from a factory or an export warehouse for consumption as supplies beyond the jurisdiction of the internal revenue laws of the United States, the manufacturer or export warehouse proprietor shall consign the shipment to the district director of customs at the port at which the shipment is to be laden. (72 Stat. 1418, as amended;

This section lists the captions that appear in the regulations under section 1031. §1.1031(a)-1 Property held for productive use in a trade or business or for investment. (a) In general. (b) Definition of “like kind.” (c

(a) General ruleOriginal issue discount on any tax-exempt obligation shall be treated as accruing— (1) for purposes of section 163, in the manner provided by section 1272(a) (determined without regard to

(a) SecuritiesNotwithstanding sections 165(g)(1) and 166(e), subsections (a) and (b) of section 166 (relating to allowance of deduction for bad debts) shall apply in the case of a bank to a debt which is evidenced by a security as defined in

general. (b) Numerator of applicable fraction. (1) In general. (2) GSTs occurring during an ETIP. (c) Denominator of applicable fraction. (1) In general. (2) Zero denominator. (3) Nontaxable gifts. (d) Examples. §26.2642-2   Valuation. (a) Lifetime transfers. (1) In general. (2) Special rule for late

section 165(a) for casualty or theft losses described in paragraph (2) or (3) of section 165(c) or for losses described in section 165(d), (4) the deductions under

Except as provided in section 132(a)(6), there shall be included in gross income (as compensation for services) any amount received or accrued, directly or indirectly, by an individual as a payment for or reimbursement of expenses of moving from one residence to another residence which is attributable to employment or self-employment.

(a) In generalFor purposes of this subpart, the term "subpart F income" means, in the case of any controlled foreign corporation, the sum of— (1) insurance income (as defined under section 953), (2) the foreign base company income (as determined under

(a) Distributable net incomeFor purposes of this part, the term "distributable net income" means, with respect to any taxable year, the taxable income of the estate or trust computed with the following modifications— (1) Deduction for distributionsNo deduction shall be taken under

issue discount on any obligation shall be reported— (i) as if paid at the time it is includible in gross income under section 1272 (except that for such purpose the amount reportable with respect to any subsequent holder shall be determined as if he were the original holder), and (ii) if

(a) General ruleFor purposes of section 38, in the case of an eligible small employer, the small employer health insurance credit determined under this section for any taxable year in the credit period is the amount determined under subsection (b). (b) Health insurance credit amount

(a) Definitions. For purposes of section 901(m), this section, and §§1.901(m)-2 through 1.901(m)-8, the following definitions apply: (1) The term aggregate basis difference means, with respect to a foreign income tax and a foreign payor, the sum of the

(a) In general. The provisions of §§1.338-1 through 1.338-7, 1.338-10 and 1.338(h)(10)-1 apply to any qualified stock purchase occurring after March 15, 2001. For rules applicable to qualified stock purchases on or before March 15, 2001, see §§1.338-1T through 1.338-7T, 1.338-10T, 1.338(h)(10)-1T and 1.338(i)-1T in effect prior to

6654 or 6655 with respect to such failure. In the case of a willful violation of any provision of section 6050I, the first sentence of this section shall be applied by substituting "felony" for "misdemeanor" and "5 years" for "1 year".

section 167, 169, 179, 185, 190, 193, or 194". 1986—Pub. L. 99–514, §201(d)(2)(A), in amending section generally, substituted provision relating to amortization of cost of acquiring a lease, subsec. (a) setting out a general rule and subsec. (b) excluding certain periods, for former provision for depreciation or amortization of improvements made by lessee on lessor's property, subsec. (a) setting

allocation or ownership equal to 50 percent of the amount involved. (b) Prohibited allocationFor purposes of this section, the term "prohibited allocation" means— (1) any allocation of qualified securities acquired in a sale to which section 1042 applies which violates the provisions of

(a) Treatment as expensesNotwithstanding section 263, there shall be allowed as a deduction any domestic research or experimental expenditures which are paid or incurred by the taxpayer during the taxable year. (b) Domestic research or experimental expendituresFor purposes of this