continental shelf areasThe principles of section 638 shall apply for purposes of the term "United States". (C) United States includes foreign trade zonesThe term "United States" includes any foreign trade zone of the United States. (5) United States refineryThe term "United States refinery

(i) Under section 535(b)(1), the deduction for taxes is the excess of— (A) The consolidated liability for tax determined without §1.1502-2(a)(2) through (4), and without the foreign tax credit provided by section 27, over (B) The consolidated foreign tax credit determined pursuant to

(within the meaning of section 2503(e)(2)) or any distribution properly disclosed in a return under section 6048(c). (c) Penalty for failure to file information (1) In generalIf a United States person fails to

(a) In generalEach material advisor (as defined in section 6111) with respect to any reportable transaction (as defined in section 6707A(c)) shall (whether or not required to file a return under

(a) In general. Section 2 of the Act of September 26, 1961 (Pub. L. 87-321, 75 Stat. 683), provides that certain taxpayers may elect to apply the provisions of such section to all taxable years beginning before January 1, 1961, with respect to which the election is effective. Section 2 of the Act prescribes special rules for the application of section 613(c) of the Internal Revenue Code of 1954 (and corresponding provisions of

sentence, the term "controlled group" has the meaning assigned to it by section 1563(a), except that the phrase "more than 50 percent" shall be substituted for the phrase "at least 80 percent" each place it appears in section 1563(a)(1). (B) Partnerships and S

(a) In general. Except as provided in paragraph (b) of this section, no deduction otherwise allowable is allowed under Chapter 1 of the Internal Revenue Code for any amount paid or incurred by a corporation in connection with the reacquisition of its stock or the stock of any related person (as defined in section 465(b)(3)(C)). Amounts paid or incurred in connection with the reacquisition of stock include amounts paid by a

§ 146.5 Specific provisions for all participating flocks. (a) Participating flocks, and all equipment used in connection with the flocks, shall be separated from non-participating flocks in a manner acceptable to the Official State Agency. (b) Poultry equipment, and poultry houses and the land in the

(C) the number of individuals with respect to whom, on the basis of facts existing at the beginning of such day, there may reasonably be expected to be allowable a credit under section 24 (determined after application of subsection (j) thereof) for the taxable year under subtitle A in respect of which amounts deducted and withheld under this chapter in the calendar year in

(3) Foreign taxesA foreign tax includes only a tax imposed by the authority of a foreign country. (4) Special rules for GST tax (A) In generalThe GST tax imposed on income distributions is— (i) the tax imposed by section 2601, and

"distributed amount" means, with respect to any calendar year, the sum of— (A) the deduction for dividends paid (as defined in section 561) during such calendar year, and (B) any amount on which tax is imposed under subsection (b)(1) or (b)(3)(A) of

) General rule for carrybacks and carryovers. Except as provided in section 172 (b)(1)(C), (D), (E), (F), (G), (H), (I), and (J), paragraphs (a)(1)(iii), (iv), (v), and (vi) of this section, and §1.172-10(a), a net operating loss shall be carried back to the 3 preceding taxable years and carried over to the 15 succeeding taxable years (5 succeeding taxable years

on such private foundation for the taxable year under subtitle A and section 4940. (e) Minimum investment return (1) In generalFor purposes of subsection (d), the minimum investment return for any private foundation for any taxable year is 5 percent of the excess of—

For a definition of the term “withholding agent” see §1.1441-7(a). Any other terms that are defined in section 7701 and that are not defined in §§301.7701-1 to 301.7701-15, inclusive, shall, when used in this chapter, have the meanings assigned to them in section

Failure to file. If an organization required to file a return under section 6033 fails to file an information return on magnetic media when required to do so by this section, the organization is deemed to have failed to file the return. (See section 6652 for the addition to tax for failure to file a return.) In determining whether there is reasonable cause for failure to file the return, §301.6652