foreign corporation. Paragraph (c) of this section defines a third-country transaction, and paragraph (d) of this section provides other definitions. Paragraph (e) of this section provides operating rules. Paragraph (f) of this section provides an example illustrating the application of the rules of this section. Paragraph (g) of this section provides the dates of applicability. See §1.7874-1(d)(1) for

apportion either a consolidated section 382 limitation or a subgroup section 382 limitation. (3) Coordination with §§1.1502-91A through 1.1502-93A. For rules regarding the determination of whether there is an ownership change of a loss subgroup and the computation of a subgroup section 382 limitation following such an ownership

. (d)(1). Pub. L. 101–239, §7622(a), substituted "serial payments" for "payments" in heading and amended text generally. Prior to amendment, text read as follows: "Amounts paid or incurred during the taxable year on account of a transfer, sale, or other disposition of a franchise, trademark, or trade name which are contingent on the productivity, use, or disposition of the franchise, trademark, or trade name transferred shall be allowed as a deduction under

stock option merely because the optionee may exercise the option with previously acquired stock of the corporation that granted the option or stock of the corporation whose stock is being offered for purchase under the option. For special rules relating to the use of statutory option stock to pay the option price of an incentive stock option, see §1.424-1(c)(3). (2

title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate. (2) ExceptionsParagraph (1) shall not apply to— (A) any addition to tax under

, cloud, or other file sharing system). For additional submission methods, please contact the person identified in the For Further Information Contact section. For the full EPA public comment policy, information about CBI or multimedia submissions, and general guidance on making effective comments, please visit https://www2.epa.gov/​dockets/​commenting-epa-dockets. FOR FURTHER INFORMATION CONTACT:

Editorial Notes Amendments 2009—Pub. L. 111–3 inserted ", processed tobacco," after "tobacco products" wherever appearing. 1976—Pub. L. 94–455, §1905(a)(28)(A), substituted "and notices" for "notices, and stamps" in section catchline.

during that calendar period by both spouses while married to each other as having been made one-half by each spouse. As to the manner and time for signifying consent, see §25.2513-2. Such consent, if signified with respect to any calendar period, is effective with respect to all gifts made to third parties during such calendar period except as follows: (1) If the

separately for each member. Therefore, an election may be made for one member that realizes excluded COD income (either actually or pursuant to paragraph (a)(3) of this section) while another election, or no election, may be made for another member that realizes excluded COD income (either actually or pursuant to paragraph (a)(3) of this section). See §1.108-4 for rules relating to the procedure for making

§40.162. (b) However, if a manufacturer is required by §40.165a to pay the tax by electronic fund transfer, the manufacturer shall prepay the tax before any tobacco products can be removed for consumption or sale by completing the return and filing it with TTB, in accordance

taxable years of the partners. For taxable years of a partnership and of a partner, see section 706 and §1.706-1. For the rules governing partnership statements to partners and nominees, see §1.6031(b)-1T. For the rules requiring the disclosure of certain transactions, see §1.6011-4T.

§1.1503(d)-7(c) Examples 6 through 8. (3) Deemed use. See paragraph (e) of this section for a deemed foreign use pursuant to the mirror legislation rule. (b) Available for use

fiduciary or overpayments of tax made by the transferor of which the transferee or fiduciary is legally entitled to credit or refund, such agreement and any extension thereof shall be deemed an agreement and extension thereof referred to in section 6511(c). (2) Extension of time for credit or refundIf the agreement is executed after the expiration of the

mismatch payer (or that is a party to a structured arrangement pursuant to which the payment is made). See §1.267A-6(c)(8) through (12) for examples illustrating the application of this section. (2) Definitions of certain terms. The following definitions apply for purposes of this section: (i) A

section 4081 was previously paid (and not credited or refunded), and (B) which is exempt from taxation under section 4082(a). (c) Cross referenceFor civil penalty for excessive claims under this section, see

(a) General ruleFor purposes of this chapter, the term "applicable rate" means, with respect to any generation-skipping transfer, the product of— (1) the maximum Federal estate tax rate, and (2) the inclusion ratio with respect to the transfer. (b) Maximum Federal estate tax rateFor purposes of subsection (a

(a) Imposition of taxThere is hereby imposed on any person who receives an excess parachute payment a tax equal to 20 percent of the amount of such payment. (b) Excess parachute payment definedFor purposes of this section, the term "excess parachute payment" has the meaning given to such term by

) if it satisfies the safe harbor matching contribution requirement of §1.401(k)-3(c). (d) Limitation on contributions—(1) General rule. A plan that provides for matching contributions meets the requirements of this section only if it satisfies the limitations on contributions set forth in this paragraph (d).

auspices of a qualifying institution and that the records are not sought for a commercial use but are sought in furtherance of scientific research. (8) The term representative of the news media refers to any person or entity that gathers information of potential interest to a segment of the public, uses its editorial skills to turn the raw materials into a distinct work, and distributes that work to an audience. The term 'news

address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1744-IFC, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850. For information on viewing public comments, see the beginning of the SUPPLEMENTARY INFORMATION section. FOR FURTHER INFORMATION CONTACT:

date of the issuance by the Secretary (or by any person or entity designated by the Secretary) of a qualified health insurance costs credit eligibility certificate for such individual for purposes of section 7527 shall not be taken into account in determining the continuous period under subparagraph (A). (ii) DefinitionsThe terms "TAA-eligible