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the Secretary and any background information related to such agreement or any application for an advance pricing agreement, and (D) any agreement under section 7121, and any similar agreement, and any background information related to such an agreement or request for such an agreement, but such term does not include data in a
(a) In general. This section sets forth the rules for determining whether a separate line of business (as determined under §1.414(r)-3) satisfies the 50-employee and notice requirements of §1.414(r-1(b)(2)(iv) (B) and (C), respectively. (b) Fifty-employee
(a)-(a)(2) [Reserved]. For further information, see §1.892-5T(a) through (a)(2). (3) For purposes of section 892(a)(2)(B), the term entity means and includes a corporation, a partnership, a trust (including a pension trust described in
percent of such portion. The penalty for disregarding rules or regulations does not apply, however, if the requirements of paragraph (c)(1) of this section are satisfied and the position in question is adequately disclosed as provided in paragraph (c)(2) of this section (and, if the position relates to a reportable transaction as defined in §1.6011-4(b) (or §1.6011-4T(b), as applicable), the
) regulations (consistent with the principles of chapters 11 and 12) providing for the application of this chapter in the case of transferors who are nonresidents not citizens of the United States, and (3) regulations providing for such adjustments as may be necessary to the application of this chapter in the case of any arrangement which, although not a trust, is treated as a trust under
Every manufacturer or importer of tobacco products, processed tobacco, or cigarette papers and tubes, and every export warehouse proprietor, shall make reports containing such information, in such form, at such times, and for such periods as the Secretary shall by regulation prescribe.
is not set out in the Code. See Publication of Harmonized Tariff Schedule note set out under section 1202 of Title 19, Customs Duties. Amendments 2000—Subsec. (d). Pub. L. 106–476 substituted "the original manufacturer of such" for "a manufacturer of" and inserted
military service, and the workings of military justice requires the exercise of sound judgment by those responsible for administering military justice and by representatives of the press and other news media. At the heart of all guidelines pertaining to the furnishing of information concerning an accused or the allegations against him is the mandate that no statements or other information shall be furnished to news media for the purpose of influencing the outcome of an accused's trial, or which could
exportationIn the case of distilled spirits withdrawn from bonded premises by the proprietor for exportation without payment of tax, the bond of such proprietor required to be furnished under paragraph (1) of section 5173(a) covering such premises shall cover such exportation, and subsection (a) shall not apply. (c) Cancellation or credit of export bonds
during the 12-month period ending on the date of the transfer) exceeds $100,000. For purposes of the preceding sentence, the value of any transferred property is its fair market value at the time of its transfer. (2) Special ruleIf by reason of an adjustment under section 482 or otherwise, a contribution described in
(ii) Dividends other than those derived from sources within the United States as provided in section 861(a)(2) and §1.861-3; (iii) Compensation for labor or personal services performed without the United States; (iv) Rentals or royalties from property located without the United States or from any
taxpayer. Any supplemental return made on such form in accordance with §31.6205-1 shall constitute a part of the return which it supplements. Except as may be provided under procedures authorized by the Commissioner with respect ot taxes imposed by the Railroad Retirement Tax Act, consolidated returns of two or more employers are not permitted, as for example, returns of a parent and a subsidiary
(a) General ruleA regulated investment company— (1) which holds (directly or indirectly) one or more tax credit bonds on one or more applicable dates during the taxable year, and (2) which meets the requirements of section 852(a) for the taxable year (determined
(a) Creation of remedyIn a case of actual controversy involving a determination by the Secretary of (or a failure by the Secretary to make a determination with respect to)— (1) whether an election may be made under section 6166 (relating to extension of time for payment of estate tax where estate
Pub. L. 100–647, title VII, §7106(b), Nov. 10, 1988, 102 Stat. 3773, provided that: "(1) In general.—In the case of any calendar month beginning before January 1, 1991— "(A) there shall be substituted for '4 percent' in subsections (a) and (b) of section
charitable deduction allowed under section 2055 or 2522 with respect to such property. (3) Severing of trusts (A) In generalIf a trust is severed in a qualified severance, the trusts resulting from such severance shall be treated as separate trusts thereafter for purposes of this chapter.