distribution, or (ii) securities in the controlled corporation are received and no securities are surrendered in connection with such distribution. (B) Stock acquired in taxable transactions within 5 years treated as bootFor purposes of this section (other than paragraph (1)(D) of this subsection) and so much of section 356

§ 102-118.80 Who is responsible for keeping my agency's electronic commerce transportation billing records? Your agency's internal financial regulations will identify responsibility for recordkeeping. In addition, the GSA Transportation Audits Division keeps a central repository of electronic

principle in section 267(a)(2) in cases in which the payee is a foreign person. Section 1.267(a)-3(b) generally requires a taxpayer to use the cash method of accounting for deductions of amounts owed to a related foreign person. An exemption is provided in § 1.267(a)-3(c)(2) for any amount

(a) The Commission issues news releases on major applications, decisions, opinions, orders, rulemakings, new publications, major personnel changes, and other matters of general public interest. Releases are issued by and available to the media from the Office of External Affairs. Releases may be obtained by the public through the Public Reference Room. (b) Press, television, radio and photographic coverage of Commission proceedings is

(a) Imposition of tax. (1) This section applies for purposes of determining the tax of a foreign corporation which at no time during the taxable year is engaged in trade or business in the United States. However, see also §1.882-2 where such corporation has an election in effect for the taxable

(2) Exempt amountFor purposes of paragraph (1), the term "exempt amount" means an amount equal to— (A) the sum of— (i) the standard deduction, and (ii) the aggregate amount of the deductions for personal exemptions allowed the taxpayer under section 151 in the taxable year

(ii) the aggregate deductions for interest properly allocable to such property, exceed (B) the aggregate income from such property. (2) Tax-exempt use property (A) In generalThe term "tax-exempt use property" has the meaning given to such term by

expenditures for depreciable propertySuch term shall not include any expenditure for the acquisition of property of a character subject to the allowance for depreciation which is used in connection with the abatement or control of hazardous substances at a qualified contaminated site; except that the portion of the allowance under section 167 for such property which is otherwise allocated to such site

(c) of §1.167(a)-1 for the definition of salvage value, the time for making the determination, the redetermination of salvage value, and the general rules with respect to the treatment of salvage value. See also section 167(g) and §1.167(g)-1 for basis for depreciation. A reduction of

), the corporate income tax imposed by section 11(a) or 1201(a). The method provided by section 860 is to allow an additional deduction for a dividend distribution (that meets the requirements of section 860 and §1.860-2) in computing the deduction for dividends paid for the taxable year for which the deficiency is determined. A deficiency divided may be an ordinary dividend or, subject to the

§ 332.7 Federal oversight of a cooperative interstate shipment program. (a) The FSIS selected establishment coordinator for a State that has entered into an agreement for a cooperative interstate shipment program will visit each selected establishment in the State on a regular basis to verify that the establishment is operating in a

(A) unless it is in cash, or (B) except in the case of contributions under subsection (c)(1)(C) or received in a qualified ABLE rollover contribution described in section 530A(d)(4)(B), if such contribution to an ABLE account would result in aggregate contributions from all contributors to the ABLE account for the taxable year

(A) the taxable income of the taxpayer for the taxable year, over (B) the net capital gain (as defined in section 1(h)) of the taxpayer for such taxable year. (b) Combined qualified business income amountFor purposes of this section— (1) In generalThe term

the United States. (b) Cross references (1) For definition of manufacturer of stills, see section 5102. (2) For definition of dealer, see section 5121(c)(3). (3) For

(C) to comply with a prohibition imposed by a country on the exportation of products obtained in such country to any country which is the object of an international boycott. (c) International boycott factor (1) International boycott factorFor purposes of sections 908(a), 952(a)(3), and 995(b)(1

shall be included with a taxpayer's return under chapter 1 for the taxable year which includes such month. (3) Payment of penaltyIf an individual with respect to whom a penalty is imposed by this section for any month— (A) is a dependent (as defined in section 152) of another taxpayer for the other taxpayer's

(a) Each importer who was liable, during a calendar year, for a gross amount equal to or exceeding five million dollars in distilled spirits taxes combining tax liabilities incurred under this part and parts 19 and 26 of this chapter, a gross amount equal to or exceeding five million dollars in wine taxes combining tax liabilities incurred under this part and parts 24 and 26 of this chapter, or a gross amount equal to or exceeding five million dollars in beer taxes

against making political expenditures, the Secretary shall immediately make a determination of any income tax payable by such organization for the current or immediately preceding taxable year, or both, and shall immediately make a determination of any tax payable under section 4955 by such organization or any manager thereof with respect to political expenditures

(a) Authority to seek injunction (1) In generalIf the requirements of paragraph (2) are met, a civil action in the name of the United States may be commenced at the request of the Secretary to enjoin any section 501(c)(3) organization from further making political expenditures and for

Par. (3). Pub. L. 106–554, §1(a)(7) [title IV, §401(b)(2)–(4)], added par. (3). 1997—Par. (1). Pub. L. 105–34 substituted "property" for "personal property (as defined in section 1092(d)(1))". 1984—Pub. L. 98–369, §102(e)(9), inserted at end "The preceding sentence shall not apply to the retirement of any debt instrument (whether or not

Aug. 16, 1954, ch. 736, 68A Stat. 620, related to packaging of distilled spirits for industrial uses, prior to the general revision of this chapter by Pub. L. 85–859. A prior section 5117, added