(a) Creation of Trust FundThere is established in the Treasury of the United States a trust fund to be known as the "Airport and Airway Trust Fund", consisting of such amounts as may be appropriated, credited, or paid into the Airport and Airway Trust Fund as provided in this section, section 9503(c)(5), or

(a) Earnings and profitsExcept as provided in section 312(k)(4), for purposes of this subpart, the earnings and profits of any foreign corporation, and the deficit in earnings and profits of any foreign corporation, for any taxable year shall be determined according to rules substantially similar to those applicable to domestic

(a) Imposition of penalty (1) In generalIf any person who is required to maintain a list under section 6112(a) fails to make such list available upon written request to the Secretary in accordance with

(a) General rule. If an employer is treated as operating qualified separate lines of business for purposes of section 410(b) in accordance with §1.414(r)-1(b) for a testing year, the requirements of section 410(b) must be applied in accordance with this section separately with respect to the employees of each qualified

) Definitions—(1) In general. In applying the provisions of this section and of §§1.414(r)-1 through 1.414(r)-10, unless otherwise provided, the definitions in this paragraph (b) govern in addition to the definitions in

(a) General definitionThe term "taxable gifts" means the total amount of gifts made during the calendar year, less the deductions provided in subchapter C (section 2522 and following). (b) Exclusions from gifts (1) In generalIn the case

(1) the deduction under section 163 (relating to interest), (2) the deduction under section 164 (relating to taxes), (3) the deduction under

private activity bond if— (A) 501(c)(3) organizations were treated as governmental units with respect to their activities which do not constitute unrelated trades or businesses, determined by applying section 513(a), and (B) paragraphs (1) and (2) of

, see sections 864(c) and 871 (c) and (d), §§1.864-3 through 1.864-7, and §§1.871-9 and 1.871-10. For special rules for determining the income of an alien individual who changes his residence during the taxable year, see

) shall not be assessed and, if assessed, the assessment shall be abated and, if collected, shall be credited or refunded as an overpayment. (b) Qualified first tier taxFor purposes of this section, the term "qualified first tier tax" means any first tier tax imposed by subchapter A, C, D, or G of this chapter, except that such term shall not include the tax imposed by

taxpayer). (2) Nonapplication of subsectionThis subsection shall not apply to— (A) a contract which constitutes property described in paragraph (1) or (7) of section 1221(a), and (B) any income derived in connection with a contract which, without regard to this subsection, is

income derived during such year from institutes and trade shows which are primarily for the education of members). If for any taxable year such deductions exceed such income, the excess shall be treated as a deduction attributable to furnishing services, insurance, goods, or other items of value to members paid or incurred in the succeeding taxable year. The deductions provided by sections 243 and 245

(a) In general. Notwithstanding the provisions of paragraph (a) of §1.50A-3, a termination of employment shall not be deemed to occur if paragraph (b) (relating to voluntary termination of employment), paragraph (c) (relating to termination of employment due to disability), paragraph (d) (relating to termination of employment due

(a) General ruleA trust shall not constitute a qualified trust under section 401(a) for any plan year if the plan of which it is a part is a top-heavy plan for such plan year unless such plan meets— (1) the vesting requirements of subsection (b), and (2) the minimum

(a) Increase in basisUnder regulations prescribed by the Secretary, the basis of a United States shareholder's stock in a controlled foreign corporation, and the basis of property of a United States shareholder by reason of which he is considered under section 958(a)(2) as owning stock of a controlled foreign corporation, shall be

(a) Civil penaltyIn addition to any criminal penalty provided by law, if any notice or return required to be filed by section 6048— (1) is not filed on or before the time provided in such section, or (2) does not include all the information required pursuant to

If there is a foreign tax credit splitting event with respect to a foreign income tax paid or accrued by a specified 10-percent owned foreign corporation (as defined in section 245A(b) without regard to paragraph (2) thereof), such tax shall not be taken into account— (1) for purposes of

(a) Requirements applicable to regulated investment companiesThe provisions of this part (other than subsection (c) of this section) shall not be applicable to a regulated investment company for a taxable year unless— (1) the deduction for dividends paid during the taxable year (as defined in section 561

(a) In general. A partnership may file a request for an administrative adjustment with respect to any partnership-related item (as defined in §301.6241-1(a)(6)(ii)) for any partnership taxable year. When filing an administrative adjustment request (AAR), the partnership must determine whether the adjustments requested in the

paragraph). For purposes of this paragraph, in the case of a personal service corporation (within the meaning of section 441(i)(2)), such corporation and any employee-owner (within the meaning of section 269A(b)(2), as modified by

(a) Creation of Trust FundThere is hereby established in the Treasury of the United States a trust fund to be known as the "Sport Fish Restoration and Boating Trust Fund". Such Trust Fund shall consist of such amounts as may be appropriated, credited, or paid to it as provided in this section, section 9503(c)(3),

(a) In generalIn the case of an eligible taxpayer which elects to transfer all (or any portion specified in the election) of an eligible credit determined with respect to such taxpayer for any taxable year to a taxpayer (referred to in this section as the "transferee taxpayer") which is not related (within the meaning of section 267(b)