taxable under section 831. (h) Treatment of deficiency reservesFor purposes of this section and section 842(b)(2)(B)(i), the terms "life insurance reserves" and "total reserves" shall not include deficiency reserves.

) shall not be assessed and, if assessed, the assessment shall be abated and, if collected, shall be credited or refunded as an overpayment. (b) Qualified first tier taxFor purposes of this section, the term "qualified first tier tax" means any first tier tax imposed by subchapter A, C, D, or G of this chapter, except that such term shall not include the tax imposed by

(a) General ruleThe amount of the taxable income of any new loss corporation for any post-change year which may be offset by pre-change losses shall not exceed the section 382 limitation for such year. (b)

(a) General ruleIf, under section 1382(b)(2) or (4), or (c)(2)(B), a deduction is allowable to an organization for the taxable year for amounts paid in redemption of nonqualified written notices of allocation or nonqualified per-unit retain certificates, then the tax imposed by this chapter on such organization for the taxable year

) Retirement planFor purposes of this section, the term "retirement plan" means— (1) a pension, profit-sharing, or stock bonus plan described in section 401(a) or a trust which is part of such a plan, or (2) an annuity plan described in

(a) Amount allocatedIn the case of a trust which is subject to subpart C, the amount of the accumulation distribution of such trust for a taxable year shall be deemed to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of each of the preceding taxable years, commencing with the earliest of

(2) Exception for liability paid by citizens or residents of the United StatesParagraph (1) shall not apply to any liability payable to the Virgin Islands under section 932(b). (3) Special rule for non-United States income of certain foreign corporations (A) In generalIn the case

occurring prior to May 10, 1989. See §1.597-8 for rules regarding FFA received or accrued on or after May 10, 1989, that relates to an acquisition that occurred before May 10, 1989. (b) Applicability date of §§1.597-1 through 1.597-6.

(a) Treatment of certain stock purchases (1) Acquisition by related corporation (other than subsidiary)For purposes of sections 302 and 303, if— (A) one or more persons are in control of each of two corporations, and

(a) General ruleFor purposes of this title, the term "private foundation" means a domestic or foreign organization described in section 501(c)(3) other than— (1) an organization described in section 170(b)(1

For purposes of this part, the term "life insurance deductions" means the general deductions provided in section 805. Editorial Notes

connection with, the conduct of a commercial banking function or other commercial activity by such bank. For purposes of this section and paragraph (i) of §1.1441-4, obligations of the United States or of any agency or instrumentality thereof include beneficial interests, participations, and other instruments issued under section 302(c) of the Federal National Mortgage Association Charter Act (

§§1.1502-31 and 1.1502-32, and earnings and profits shall be determined under §1.1502-33; and (p) The limitation on deductions provided in section 613A shall be taken into account for each member's oil and gas properties as provided in

paid after December 31, 1954, for services performed on or before such date. (4) Subtitle DSubtitle D of this title shall take effect on January 1, 1955. Subtitles B and C of the Internal Revenue Code of 1939 (except chapters 7, 9, 15, 26, and 28, subchapter B of chapter 25, and parts VII and VIII of subchapter A of chapter 27 of such code) are hereby repealed effective January 1, 1955. Provisions having the same effect as

. Paragraph (c) of this section provides rules with respect to separate units and interests in transparent entities. These determinations are required for various purposes under section 1503(d). For example, it is necessary for purposes of applying the domestic use limitation rule under §1.1503(d)-4(b) to a dual consolidated loss, and for determining the extent to which a dual consolidated loss is

section 6662A. (c) NegligenceFor purposes of this section, the term "negligence" includes any failure to make a reasonable attempt to comply with the provisions of this title, and the term "disregard" includes any careless, reckless, or intentional disregard. (d) Substantial understatement of income tax

meaning of section 1092(c), without regard to paragraph (4) thereof) as capital gain or loss (as the case may be) if the taxpayer makes such election and identifies such transaction before the close of the day on which such transaction is entered into (or such earlier time as the Secretary may prescribe). (2) Gain or loss treated as interest for certain purposes

(a) Presumed facts. For purposes of the examples in paragraph (b) of this section, assume that there are no other transactions that are related to the transactions described in the examples and that all partnership allocations have substantial economic effect under section 704(b). For definitions that apply for purposes of this section, see