) Qualified small business stockThe term "qualified small business stock" has the meaning given such term by section 1202(c). (2) PurchaseA taxpayer shall be treated as having purchased any property if, but for paragraph (3), the unadjusted basis of such property in the hands of the taxpayer would be its cost (within the meaning of

(a) Foreign base company incomeFor purposes of section 952(a)(2), the term "foreign base company income" means for any taxable year the sum of— (1) the foreign personal holding company income for the taxable year (determined under subsection (c) and reduced as provided in subsection (b)(5)),

(a) Qualified domestic trust definedFor purposes of this section and section 2056(d), the term "qualified domestic trust" means, with respect to any decedent, any trust if— (1) the trust instrument— (A) except as provided in regulations prescribed by the

advance amountFor purposes of this section— (1) In generalExcept as otherwise provided in this subsection, the term "annual advance amount" means, with respect to any taxpayer for any calendar year, the amount (if any) which is estimated by the Secretary as being equal to 50 percent of the amount which would be treated as allowed under subpart C of part IV of subchapter A of chapter 1 by reason of

of income which is taken into account under section 871(b)(1) or 882(a)(1) for the taxable year. (C) Special rule for sourcing interest paid by foreign branches of domestic financial institutionsSubparagraph (B) of section 861(a)(1) shall not apply.

penalty and forfeiture for unlawful production of distilled spirits, see sections 5601(a)(7), 5601(a)(8), and 5615(4). Editorial Notes Prior

other items of income enumerated under section 881(a). Such a foreign corporation is also taxable on certain income from sources within the United States which, pursuant to §1.882-2, is treated as effectively connected for the taxable year with the conduct of a trade or business in the United States. (2) Foreign corporations engaged in

) for any year are more than de minimis, subparagraph (A) shall be applied by substituting "$15,000" for "$2,500" with respect to such person. (C) Exception for church plansThis paragraph shall not apply to any failure under a church plan (as defined in section 414(e)). (c) Limitations on amount of tax

could cause a taxpayer with a synthetic debt instrument under § 1.1275-6 to be treated as legging out of the integrated transaction, and it also sought clarification on the source and character of a one-time payment in lieu of a spread adjustment on a derivative. The ARRC recommended treating SOFR, similar replacement rates for IBOR-referencing rates in other currencies, and potentially any qualified

Within 20 days after service of a notice of opportunity for hearing which does not fix a date for hearing the respondent, either in the answer or in a separate document, may request a hearing. Failure of the respondent to request a hearing shall be deemed a waiver of the right to a hearing and to constitute consent to the making of a decision on the basis of such information as is available. [35 FR 10760, July 2, 1970

which persons described in subparagraph (A), (B), (C), or (D) hold more than 35 percent of the beneficial interest, (H) only for purposes of section 4943, a private foundation— (i) which is effectively controlled (directly or indirectly) by the same person or persons who control the private foundation in question, or

under section 6695(d) of the Code, failure to file a correct information return under section 6695(e) of the Code, and negotiation of a check under section 6695(f) of the Code, in the manner stated in §1.6695-1 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed

list under section 6695(d) of the Code, failure to file a correct information return under section 6695(e) of the Code, and negotiation of a check under section 6695(f) of the Code, in the manner stated in §1.6695-1 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund

list under section 6695(d) of the Code, failure to file a correct information return under section 6695(e) of the Code, and negotiation of a check under section 6695(f) of the Code, in the manner stated in §1.6695-1 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund

(a) Year in which partnership income is includibleIn computing the taxable income of a partner for a taxable year, the inclusions required by section 702 and section 707(c) with respect to a partnership shall be based on the income, gain

Subsec. (b). Pub. L. 96–39, §807(a)(16)(A), substituted reference to paragraph (1) of section 5173(a) for reference to section 5173(c) and struck out provisions relating to failure or refusal of the proprietor of a distilled spirits plant to withdraw any spirits from storage on bonded premises

(1) Nonreviewability.—For nonreviewability of Tax Court decisions in small claims cases, see section 7463(b). (2) Transcripts.—For authority of the Tax Court to fix fees for transcript of records, see section 7474.

§20.2014-7 for the effect which the allowance of this deduction has upon the credit for foreign death taxes. (b) Condition for allowance of deduction. (1) The deduction is not allowed unless either— (i) The entire decrease in the Federal estate tax resulting from the allowance of the deduction inures