the United States to which such income, gain, or loss is attributable and such income, gain, or loss— (i) consists of rents or royalties for the use of or for the privilege of using intangible property described in section 862(a)(4) derived in the active conduct of such trade or business; (ii) consists of dividends, interest

(a) General rule. Sections 1.883-1 through 1.883-4 apply to taxable years of a foreign corporation seeking qualified foreign corporation status beginning after September 24, 2004. (b) Election for retroactive application. Taxpayers may elect to apply

(a) General ruleA taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such

§1.415(b)-1. (2) In the case of a defined contribution plan, the annual additions credited with respect to any participant for any limitation year exceed the limitations of section 415(c) and §1.415(c)-1. (3) The trust has been disqualified under

general. (b) Duress. (c) Prior closing agreement or offer in compromise. (1) In general. (2) Exception for agreements relating to TEFRA partnership proceedings. (3) Examples. (d) Fraudulent scheme. (e) Res judicata and collateral estoppel. (f) Community property laws. (1) In general. (2) Example. (g) Scope of this section and

(a) Who is eligible to apply for a planning grant that will be awarded before a tribe/consortium is admitted into the applicant pool? Any tribe/consortium that is not a self-governance tribe and needs advance funding in order to complete the planning phase requirement may apply. Tribes/consortia that have received a planning grant within 3 years preceding the date of the latest Federal Register

section 2(a)), the applicable dollar amount and the phaseout range shall be ½ of the amounts applicable under subparagraph (A) (as so adjusted). (c) Eligible individualFor purposes of this section— (1) In generalThe term "eligible individual" means any individual if such individual has attained the age of 18 as of the close

requirements of this chapter shall not apply to any group health plan in relation to its provision of excepted benefits described in section 9832(c)(1). (c) Exception for certain benefits if certain conditions met (1) Limited, excepted benefitsThe requirements of this chapter shall not apply to any group health

(a) In generalAny imputed underpayment shall be assessed and collected in the same manner as if it were a tax imposed for the adjustment year by subtitle A, except that— (1) subchapter B of chapter 63 shall not apply, and (2) in the case of an administrative adjustment request to which

petition" in section catchline. Pub. L. 117–58, §80503(a), designated existing provisions as subsec. (a), inserted heading, and added subsec. (b). 2006—Pub. L. 109–280 struck out "for the redetermination of a deficiency or for a declaratory judgment under part IV of this subchapter or under