(a) Amounts included (1) In generalIf a foreign corporation is a controlled foreign corporation at any time during a taxable year of the foreign corporation (in this subsection referred to as the "CFC year")— (A) each United States shareholder which owns (within the meaning of

Except as otherwise provided in this subchapter, and except as otherwise provided in section 28(a) of the Revised Organic Act of the Virgin Islands and section 30 of the Organic Act of Guam (relating to the covering of the proceeds of certain taxes into the

(a) In generalFor purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate the amount of all bequests, legacies, devises, or transfers— (1) to or for the use of the United States, any State, any political

(a) Gain on exchanges (1) Recognition of gainIf— (A) section 354 or 355 would apply to an exchange but for the fact that (B) the property received in the exchange consists not only of property permitted by

corporation, if a return is made for a short period by reason of subsection (a)(1) and if the tax is not computed under subsection (b)(2), then the exemptions allowed as a deduction under section 151 (and any deduction in lieu thereof) shall be reduced to amounts which bear the same ratio to the full exemptions as the number of months in the short period bears to 12. (d

(a) A proprietor may withdraw spirits from bonded premises without payment of tax for: (1) Export, as authorized under 26 U.S.C. 5214(a)(4); (2) Transfer to customs manufacturing bonded warehouses, as authorized under

(a) If the certificate required by §26.205 covers distilled spirits, and the distilled spirits are not being transferred under subparts O or Oa of this part, the tax imposed by 26 U.S.C. 7652 which provides for a tax equal to the tax imposed by

corporation"As used in this chapter, the term "includible corporation" means any corporation except— (1) Corporations exempt from taxation under section 501. (2) Insurance companies subject to taxation under section 801.

(a) In general. Except as otherwise provided in paragraph (b) of this section, the regulations under sections 860A through 860G are effective only for a qualified entity (as defined in §1.860D-1(c)(3)) whose startup day (as defined in section 860G(a)(9) and

(a) General ruleIn the case of a nonresident alien individual, the deductions shall be allowed only for purposes of section 871(b) and (except as provided by subsection (b)) only if and to the extent that they are connected with income which is effectively connected with the conduct of a trade or business within the United States; and

(a) Constructive ownershipFor purposes of determining whether a corporation is a personal holding company, insofar as such determination is based on stock ownership under section 542(a)(2), section 543(a)(7),

(a) General ruleThe basis of partnership property shall not be adjusted as the result of a distribution of property to a partner unless the election, provided in section 754 (relating to optional adjustment to basis of partnership property), is in effect with respect to such partnership or unless there is a substantial basis reduction

(2) Adjustments for redemptions, liquidations, reorganizations, divisives, etc.In the case of any transaction involving the application of subchapter C to any S corporation, proper adjustment to any accumulated earnings and profits of the corporation shall be made. (3) Adjustments in case of distributions treated as dividends under section 1368(c)(2

(a) General ruleIn the case of any interest in qualified real property (within the meaning of section 2032A(b)), an amount equal to the adjusted tax difference attributable to such interest (within the meaning of section 2032A(c)(2)(B)

(a) Prohibitions (1) Federal employees and other personsIt shall be unlawful for— (A) any officer or employee of the United States, or (B) any person described in subsection (l)(18) or (n) of section 6103 or an

(a) Treatment of expatriatesA tax computed in accordance with the table contained in section 2001 is hereby imposed on the transfer of the taxable estate, determined as provided in section 2106, of every decedent nonresident not a citizen

This section lists the section headings and undesignated center headings that appear in the regulations under section 2031. §20.2031-1   Definition of gross estate; valuation of property.