(b) For the purposes of this section, a taxpayer includes a controlled group of corporations, as defined in 26 U.S.C. 1563, and implementing regulations in 26 CFR 1.1563-1 through 1.1563-4, except that the words “at least 80 percent” shall be replaced by the words “more than 50 percent” in each place it appears in subsection (a) of

(a) Initial taxes (1) On self-dealerThere is hereby imposed a tax on each act of self-dealing between a disqualified person and a trust described in section 501(c)(21). The rate of tax shall be equal to 10 percent of the amount involved with respect to the act of self-dealing for each

Section 1.410(a)-4 provides rules under section 410(a) (2) and (4) relating to maximum age and time of participation. (5) Year of service; breaks in service. For rules relating to years of service and breaks in service, see 29 CFR Part 2530 (Department of Labor regulations relating to minimum standards for employee pension benefit plans

person operating the bonded premises of the distilled spirits plant to which such spirits are transferred shall become liable for the tax on distilled spirits withdrawn from customs custody under this section upon release of the spirits from customs custody, and the importer, or the person bringing such distilled spirits into the United States, shall thereupon be relieved of his liability for such tax. (b) Withdrawals, etc.Distilled spirits

principal purpose of using one or more built-in loss RFAs to avoid the application of section 901(m). Furthermore, a basis difference with respect to a built-in loss RFA will not be taken into account for purposes of the cumulative basis difference exemption or the RFA class exemption under §1.901(m)-7 if any RFAs, including RFAs other than built-in loss RFAs, are acquired with a principal purpose

rate of withholding with respect to that income in the same manner as a foreign person that is not a tax-exempt organization. See §1.1441-9(b)(3) for a presumption that amounts are includible under section 512 and section 513 in computing the organization's unrelated business taxable income in the absence of reliable certification. See also

Code of 1939 were repealed by section 7851(a)(1)(A) of this title, and chapters 3 and 4 of the Internal Revenue Code of 1939 were repealed by section 7851(a)(2)(A) of this title. For table of comparisons of the 1939 Code to the 1986 Code, see Table I preceding

occur on or after October 5, 2016. For any transaction with respect to which all transfers that are part of a sale of an item of property occur after April 24, 1991, and any of such transfers occurs before October 5, 2016, §§1.707-3 through 1.707-6 as contained in 26 CFR part 1 revised as of April 1, 2016, apply. (2) Transfers occurring

Any person who engages in a business taxable under 26 U.S.C. 5801, without timely payment of the tax imposed with respect to such business (see §479.34) shall be liable for such tax, plus the interest and penalties thereon (see

hire, the term "value" means the actual charge paid for such service or the prevailing charge for comparable service if no actual charge is paid. (b) Special rule for Alaska, Hawaii, and possessions (1) In generalNo tax shall be imposed under section 4461(a) with respect to—

disclosed by such return (or amended return). For purposes of section 6511, such claim shall be considered as filed on the date on which such return (or amended return) is considered as filed, except that if the requirements of §301.7502-1, relating to timely mailing treated as timely filing are met, the claim shall be considered to be filed on the date of the postmark stamped on the cover in which the

section 451(b)(5) shall apply. (B) Consolidated returnsExcept as provided in regulations prescribed by the Secretary, if the taxpayer is part of an affiliated group of corporations filing a consolidated return for any taxable year, adjusted financial statement income for such group for such taxable year shall take into account items on the group's applicable financial

Editorial Notes Amendments 2004—Pub. L. 108–357 inserted "under section 937(c) or" before "by regulations" and substituted "$1,000" for "$100". 1976—Pub. L. 94–455 struck out "or his delegate" after "Secretary".

(a) In general. This section provides examples that illustrate the application of §§1.1503(d)-1 through 1.1503(d)-6. This section also provides facts that are presumed for such examples. (b) Presumed facts for examples. For purposes of the examples in

apply to such distribution, and (B) such distribution shall be treated as a distribution of property to which section 301 applies. (2) Applicable holding companyFor purposes of this subsection: (A) In generalThe term "applicable holding company" means any domestic

6044 (relating to payments of patronage dividends) but only to the extent such payment is in money. (B) Special rule for patronage dividendsFor purposes of subparagraphs (C) and (D) of subsection (a)(1), the term "reportable interest or dividend payment" shall not include any payment to which section 6044 (relating to patronage dividends) applies

I request that a copy of the following documents [or documents containing the following information] be provided to me: [identify the documents or information as specifically as possible]. [Sample requester descriptions] —A representative of the news media affiliated with the ____ newspaper (magazine, television station, etc.) and this request is made as part of news gathering and not for commercial use

Except as provided in §55.6091-2 (relating to exceptional cases): (a) In general. Chapter 44 tax returns shall be filed with any person assigned the responsibility to receive returns in the local Internal Revenue Service office serving the principal place of business or principal office or agency

(a) DeductionIn the case of any trust the terms of which— (1) provide that all of its income is required to be distributed currently, and (2) do not provide that any amounts are to be paid, permanently set aside, or used for the purposes specified in section 642(c)

(a) Burden of proofIn any proceeding involving the issue of whether or not any person is liable for a penalty under section 6700, 6701, or 6702, the burden of proof with respect to such issue shall be on the Secretary. (b) Deficiency procedures not to applySubchapter B of chapter 63

(a) Foreign insurer or reinsurerFor purposes of section 4371, the term "foreign insurer or reinsurer" means an insurer or reinsurer who is a nonresident alien individual, or a foreign partnership, or a foreign corporation. The term includes a nonresident alien individual, foreign partnership, or foreign corporation which shall become

parties timely requests for redetermination of a claim determination, consistent with §405.944(c), the contractor must issue a redetermination or dismissal within 60 calendar days of the latest filed request. (3) If a party submits additional evidence after the request for redetermination is filed, the contractor's 60 calendar day decision-making time frame is extended

allocated to, and considered paid or accrued by, a section 901(m) payor, the allocable foreign income of the section 901(m) payor is determined in accordance with the principles of §1.1502-76(b). To the extent the foreign income tax amount is allocated to an entity that is a partnership for U.S. income tax purposes, a portion of the foreign income is first allocated to the partnership in accordance with

(a) In general. An eligible taxpayer that elects the application of section 468A pursuant to the rules contained in §1.468A-7 (an electing taxpayer) is allowed a deduction for the taxable year in which the taxpayer makes a cash payment (or is deemed to make a cash payment as provided in paragraph (c) of this section) to a nuclear

manner provided in this section. See section 1504(e) for tax-exempt corporations eligible to file a consolidated return. (2) Applicability of other consolidated return provisions. The provisions of §1.1502-1 through §1.1502-80