(a) Overview. This section prescribes methods of allocating costs to long-term contracts accounted for using the percentage-of-completion method described in §1.460-4(b) (PCM), the completed-contract method described in §1.460-4(d

(2) Adverse determinationsFor purposes of paragraph (1), an adverse determination is described in this paragraph if such determination is adverse to an organization with respect to— (A) the initial qualification or continuing qualification of the organization as exempt from tax under section 501(a) or as an organization described in

applies as if the section 965(a) inclusion, translated (if necessary) into the functional currency of the deferred foreign income corporation using the spot rate on December 31, 2017, were a dividend paid by the deferred foreign income corporation. For purposes of computing the amount of foreign income taxes deemed paid under section 960(a)(1), §§1.965-2(b), 1.965-5, sections 902 and 960, the

Sections 5671, 5673, 5684, 6651, and 6656 of Title 26 United States Code provide penalties for evasion or failure to pay tax on beer or for failure to file a tax return. (Act of Aug. 16, 1954, 68A Stat. 821, as amended, 826, as amended (26 U.S.C. 6651, 6656); sec. 201, Pub. L. 85-859, 72 Stat. 1408, 1410, as amended (

security was acquired or by reference to other property held at any time by the dealer. See §1.475(a)-3 for rules governing how the dealer accounts for such a security if this identification is not made. (c) Integrated transactions under

(ii) 95 percent or more of such foreign corporation's gross receipts (as defined in §1.993-6) for its taxable year ending with or within such taxable year of the DISC consists of qualified export receipts described in §1.993-1 (b) through (e) or interest described in

The running of the period of limitations on collection after assessment prescribed in 26 U.S.C. 6502 (relating to collection after assessment) shall be suspended for a period equal to a period beginning on the date property (including money) is wrongfully seized or received by an appropriate TTB officer and ending on the date 30 days after the date on which the

Editorial Notes Amendments 1977—Pub. L. 95–30 substituted "section 63" for "

Editorial Notes Amendments 1977—Pub. L. 95–30 substituted "section 63" for "

(a) General rule—(1) Targeted jobs credit. For taxable years beginning after December 31, 1978, the amount of the targeted jobs credit allowed by section 44B (as amended by the Revenue Act of 1978) shall not exceed 90 percent of the tax imposed by chapter 1, reduced by the credits enumerated in section 53(a). (2) New jobs

(a) through (c) [Reserved]. For further guidance, see §1.987-8(a) through (c). (d) Annual deemed termination election. A taxpayer, including a taxpayer described in §1.987-1(b)(1)(ii) to which

§20.2031-1 for the circumstances under which real property situated outside the United States is excluded from the gross estate of a citizen or resident of the United States. However, except as provided in section 2107(b) with respect to the estates of certain expatriates, in the case of a nonresident not a citizen, only that part of the entire gross estate which on the date of the decedent's death is situated in the United States is included in his taxable estate. In fact

Subsidiaries Effective Date Section applicable to taxable periods the due date for filing returns for which (without extension) occurs after Dec. 31, 1988, see section 1012(aa)(5)(D) of Pub. L. 100–647, set out as a note under

In any proceeding involving the issue of whether or not a tax return preparer has willfully attempted in any manner to understate the liability for tax (within the meaning of section 6694(b)), the burden of proof in respect to such issue shall be upon the Secretary.

26 U.S.C. 5001, determined at the time of withdrawal from bond, on the Puerto Rican or Virgin Islands spirits, or on the rum imported from any other area, contained in the product. (d) Products subject to 26 U.S.C. 5010 tax credits. A claim for credit or refund of tax on spirits containing eligible wine or

See §1.671-5 for the reporting rules for widely held fixed investment trusts (as defined under that section). [T.D. 9241, 71 FR 4025, Jan. 24, 2006]

See §1.671-5 for the reporting rules for widely held fixed investment trusts (as defined under that section). [T.D. 9241, 71 FR 4025, Jan. 24, 2006]

(a) Scope. This section provides rules regarding whether transferred stock is treated as held by members of the EAG for purposes of applying section 7874(c)(2)(A) and §1.7874-1. Paragraph (b) of this section sets forth the general rule under which transferred stock is not treated as held by members of the EAG for purposes of

reconciliation for RHCs or FQHCs that are authorized to bill under the reasonable cost system. (1) The total reimbursement amount due the RHC or FQHC for covered services furnished to Medicare beneficiaries is based on the report specified in §405.2470(c)(2) and is calculated by the MAC as follows: (i) The average cost per visit is

a refunding issue. See §1.148-10(d), Example 4. (c) Unrefunded debt service remains eligible for future advance refunding. For purposes of section 149(d)(3)(A)(i), any principal or interest on a prior issue that has not been paid or provided for by any advance refunding issue is treated