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(a) General ruleIf the amount distributed during the taxable year of the payee under any qualified retirement plan or any eligible deferred compensation plan (as defined in section 457(b)) is less than the minimum required distribution for such taxable year, there is hereby imposed a tax equal to 25 percent of the amount by which such
transition date. This deemed transfer of assets and liabilities is taken into account only for purposes of transitioning to these regulations under section 987 and shall not be taken into account in determining the amounts transferred from the owner to the section 987 QBU during the taxable year for purposes of §1.987-5(c)(1)(ii).
(2)
;
(2) Sums offered for purchase of real estateSums offered for the purchase of real estate under the provisions of section 7506;
(3) Surplus proceeds in sales under levySurplus proceeds in any sale under levy, after making allowance for the amount of the tax, interest, penalties, and additions
(a) In generalIn the case of an eligible taxpayer which elects to transfer all (or any portion specified in the election) of an eligible credit determined with respect to such taxpayer for any taxable year to a taxpayer (referred to in this section as the "transferee taxpayer") which is not related (within the meaning of section 267(b)
section 1(f)(3) for such calendar year by substituting "calendar year 1997" for "calendar year 2016" in subparagraph (A)(ii) thereof.
If any amount as adjusted under the preceding sentence is not a multiple of $1,000, such amount shall be rounded to the next lowest multiple of $1,000.
(c) Transfer for the benefit of minorNo part of a gift to an individual who has not attained the age of 21 years
section 141(b) were applied by substituting "5 percent" for "10 percent" each place it appears and by substituting "net proceeds" for "proceeds" each place it appears.
(b) $150,000,000 limitation on bonds other than hospital bonds
(1) In generalA bond (other than a qualified hospital bond) shall not be treated as a qualified 501(c)(3) bond if the aggregate authorized face amount of the
Amendments
1986—Pub. L. 99–514 amended section generally, substituting provisions relating to taxable amount in case of a taxable distribution for former provisions which related generally to administration of this chapter. See section 2661 of this title.
section 5505(a),
shall be immediately due and payable at the time provided by such provisions (or if no specific time for payment is provided, at the time the event referred to in such provision occurs). Such taxes and amounts shall be assessed and collected by the Secretary on the basis of the information available to him in the same manner as taxes payable by return but with respect to which
consolidated return shall be treated as 1 taxpayer for purposes of this subsection.
(3) Coordination with section 172Any excess inclusion for any taxable year shall not be taken into account—
(A) in determining under section 172
company for such year.
(B) Total insurance liabilitiesFor purposes of this paragraph—
(i) Companies taxable under part IIn the case of a company taxable under part I, the term "total insurance liabilities" means the sum of the total reserves (as defined in section 816(c)) plus (to the extent not
For exception for a sale to an Indian tribal government (or its subdivision) for the exclusive use of an Indian tribal government (or its subdivision), see section 7871.
Editorial Notes
section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting "2004" for "2016" in subparagraph (A)(ii) thereof.
If any increase determined under the preceding sentence is not a multiple of $100, such increase shall be rounded to the next lowest multiple of $100.
(c) Housing cost amountFor purposes
Q&A-1—Q&A-8: [Reserved]. See §1.414(q)-1T, Q&A-1 through Q&A-8 for further guidance.
Q-9: How is the top-paid group determined?
A-9: (a) [Reserved]. See §1.414(q)-1T, Q&
(1) In generalAmounts in the Superfund shall be available, as provided in appropriation Acts, only for purposes of making expenditures—
(A) to carry out the purposes of—
(i) paragraphs (1), (2), (5), and (6) of section 111(a) of CERCLA as in effect on the date of the enactment of the Superfund
(a) Inspection of books, papers, records, or other dataFor inspection of books, papers, records, or other data in the case of—
(1) Wagering, see section 4423.
(2) Alcohol, tobacco, and firearms taxes, see subtitle E.
(b) Search warrants
(b) Where amount depends on income or profits of any person. Except as provided in paragraph (d) of this section, any amount received or accrued, directly or indirectly, with respect to an obligation is not includable as interest for purposes of section 856(c) (2)(B) and (3)(B) if, under the principles set forth in paragraphs (b)(3) and (6)(i) of §1.856-4
(a) Earnings and profitsExcept as provided in section 312(k)(4), for purposes of this subpart, the earnings and profits of any foreign corporation, and the deficit in earnings and profits of any foreign corporation, for any taxable year shall be determined according to rules substantially similar to those applicable to domestic
performed in the employ of an entity that is treated as a corporation under §301.7701-2(c)(2)(iv)(B) of this chapter may qualify for the exemption if the requirements of the exemption are otherwise met. An entity that is treated as a corporation under §301.7701-2(c)(2)(iv)(B) of this chapter is not
For purposes of this subchapter—
(1) PartnershipThe term "partnership" means any partnership required to file a return under section 6031(a).
(2) Partnership adjustment
(A) In generalThe term "partnership
section 755.
(d) Substantial basis reduction
(1) In generalFor purposes of this section, there is a substantial basis reduction with respect to a distribution if the sum of the amounts described in subparagraphs (A) and (B) of subsection (b)(2) exceeds $250,000.
(2) RegulationsFor
consistent with the method of computing interest under section 1272(a), is properly allocable to such payment.
(b) Total unstated interestFor purposes of this section, the term "total unstated interest" means, with respect to a contract for the sale or exchange of property, an amount equal to the excess of—
(1) the sum of
section 26(b)) of the taxpayer for the taxable year, reduced (but not below zero) by the excess (if any) of—
(i) the credits allowed under this chapter against such regular tax liability, over
(ii) the sum of—
(I) the credit allowed under
Court.
(d) Decisions relating to estate tax extended under section 6166If with respect to a decedent's estate subject to a decision of the Tax Court—
(1) the time for payment of an amount of tax imposed by chapter 11 is extended under
(a) Application of definitions. The definitions set forth in this section are applicable for purposes of §1.403(b)-1, this section and §§1.403(b)-3 through 1.403(b)-11.
(b)