(2) Eligible TAA recipient (A) In generalExcept as provided in subparagraph (B), the term "eligible TAA recipient" means, with respect to any month, any individual who is receiving for any day of such month a trade readjustment allowance under chapter 2 of title II of the Trade Act of 1974 or who would be eligible to receive such allowance if

(a) Effective date—(1) In general. Except as provided in §1.1502-99(b), §§1.1502-91A through 1.1502-96A and 1.1502-98A apply to any testing date on or after January 1, 1997, and before

falsity or fraud is with the knowledge or consent of the person authorized or required to present such return, affidavit, claim, or document); (4) for the offense of willfully failing to pay any tax, or make any return (other than a return required under authority of part III of subchapter A of chapter 61) at the time or times required by law or regulations; (5) for offenses described in

(a) General ruleNotwithstanding section 263, all expenditures (other than expenditures for the purchase of land or depreciable property or for the acquisition of circulation through the purchase of any part of the business of another publisher of a newspaper, magazine, or other periodical) to establish, maintain, or increase the

(a) General ruleIn the case of a married couple 1 or both of whom are nonresident alien individuals and who have community income for the taxable year, such community income shall be treated as follows: (1) Earned income (within the meaning of section 911(d)(2)), other than trade or business income

misdemeanor and, upon conviction thereof, shall be fined not more than $25,000 ($100,000 in the case of a corporation), or imprisoned not more than 1 year, or both, together with the costs of prosecution. In the case of any person with respect to whom there is a failure to pay any estimated tax, this section shall not apply to such person with respect to such failure if there is no addition to tax under section

(a) General actuarial valuations. (1) Except as otherwise provided in this section and in §20.7520-3 (relating to exceptions to the use of prescribed tables under certain circumstances), in the case of estates of decedents with valuation dates after April 30, 1989, the fair market value of

(a) Old-age, survivors, and disability insuranceIn addition to other taxes, there is hereby imposed on the income of every individual a tax equal to 6.2 percent of the wages (as defined in section 3121(a)) received by the individual with respect to employment (as defined in

(a) In general. Each reviewed year partner (as defined in §301.6241-1(a)(9)) is required to take into account its share of adjustments requested in an administrative adjustment request (AAR) that either do not result in an imputed underpayment (as described in

Commission's equipment authorization rules. DATES: Comments are due February 11, 2021. Reply comments are due February 26, 2021. FOR FURTHER INFORMATION CONTACT: Brian Butler, Office of Engineering and Technology, 202-418-2702, Brian.Butler@fcc.gov, or Thomas

. This subsection shall apply only with respect to the amount of such expenditures which, but for this subsection, would not be allowable as a deduction for the taxable year. This subsection shall not apply to expenditures for the acquisition or improvement of property of a character which is subject to the allowance for depreciation provided in section 167, but allowances for depreciation shall be

(a) Distilled spirits of Puerto Rican manufacture, and any products containing such distilled spirits, brought into the United States and withdrawn for consumption or sale are subject to a tax equal to the tax imposed in the United States by 26 U.S.C. 5001. (b) A credit against the tax imposed on distilled spirits by

Any portion of an internal revenue tax (or any interest, assessable penalty, additional amount, or addition to tax) which has been erroneously refunded, and which is recoverable by suit pursuant to section 7405, shall bear interest at the underpayment rate established under

(a) General ruleIf— (1) a partnership has effectively connected taxable income for any taxable year, and (2) any portion of such income is allocable under section 704 to a foreign partner, such partnership shall pay a withholding

decedent's gross estate under section 2036, 2037, 2038, or 2042 if such transferred interest or relinquished power had been retained by the decedent on the date of his death, the value of the gross estate shall include the value of any property (or interest therein) which would have been so included. (b) Inclusion of gift tax on gifts

such taxable year in connection with the taxpayer's trade or business and which are attributable to foreign research (within the meaning of section 41(d)(4)(F)). (c) Special rules (1) Land and other propertyThis section shall not apply to any expenditure for the acquisition or improvement of land, or for the

For a definition of the term “withholding agent” see §1.1441-7(a). Any other terms that are defined in section 7701 and that are not defined in §§301.7701-1 to 301.7701-15, inclusive, shall, when used in this chapter, have the meanings assigned to them in section

within the meaning of section 469 and the regulations thereunder. (2) Application of income recharacterization rules—(i) Income and gain recharacterization. To the extent that any income or gain from a trade or business is recharacterized as “not from a passive activity” by reason of §1.469

(a) Scope—(1) In general. This section applies section 382 and the regulations thereunder to a corporation that is a new loss member of a consolidated group. A corporation is a new loss member if it— (i) Carries over a net operating loss that arose (or is treated under

(a) Notice and demand. (1) The Internal Revenue Service (IRS) shall issue to each tax return preparer or appraiser one or more statements of notice and demand for payment for all penalties assessed against the tax return preparer or appraiser under section 6694 and §1.6694-1, under section 6695

subsection could be administratively resolved. Subsection (b) of the section clarifies the process by which the FLRA will resolve matters under various factual scenarios. Section 2424.31 is amended to include a new heading that more accurately reflects its contents, and to make other minor wording changes.

(a) General ruleFor purposes of this subtitle, the term "personal holding company" means any corporation (other than a corporation described in subsection (c)) if— (1) Adjusted ordinary gross income requirementAt least 60 percent of its adjusted ordinary gross income (as defined in