obligations defined. (3) Safe harbor for entities formed to liquidate assets. (g) Anti-avoidance rules. (1) In general. (2) Certain investment trusts. (3) Examples. §301.7701(i)-2   Special rules for portions of entities. (a) Portion defined. (b) Certain assets and rights to assets disregarded. (1) Credit enhancement

Subject to the requirements of this subpart E, you do not need OCC approval under subpart B if you conduct fiduciary activities in the following fiduciary capacities: (a) Trustee of a trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan qualifying for specific tax treatment under section 401(d) of the Internal Revenue Code of 1954 (

Spirits which have been lawfully withdrawn without payment of tax under the provisions of this subpart for exportation, or for deposit in a foreign-trade zone, a manufacturing bonded warehouse, or a customs bonded warehouse, or for use on vessels and aircraft may, subject to the requirements of §28.116, be returned: (a) To the bonded

subsequent to the date of death pursuant to the provisions of section 2032. Duplicate copies of the return are not required to be filed. For the contents of the return, see §20.6018-3. (b) Estates of nonresidents not citizens—(1) In general. Except as provided in subparagraph (2) of this

year under section 951(a) and paragraph (a) of §1.951-1 any amount attributable to the earnings and profits of such corporation for that taxable year of such corporation. If a foreign corporation is both a foreign personal holding company and a controlled foreign corporation for the same period which is only a part of its taxable year, then, for purposes of applying the immediately preceding sentence

the contract in a fiduciary capacity solely for the benefit of applicable exempt organizations or persons otherwise described in subclause (I) or clause (i) or (ii). (3) Applicable exempt organizationThe term "applicable exempt organization" means— (A) an organization described in section 170(c),

of another corporation, see paragraph (a)(6) of §1.1563-1. (2) Stock treated as not outstanding. If the provisions of this subparagraph apply, then for purposes of determining whether the parent corporation or the subsidiary corporation is a member of a parent-subsidiary controlled group of corporations within the meaning of

section and amending sections 263, 1245, and 1250 of this title] shall apply to taxable years beginning after December 31, 1976." Savings Provision For provisions that nothing in amendment by

any Net Worth Assistance that an Agency provides to the New Entity or the Acquiring in connection with the transfer. (See §1.597-2(a) and (c) for rules regarding the inclusion of FFA in income and §1.597-2(a)(1) for related rules regarding FFA provided to shareholders.) The Net Worth Assistance is

Section 174 provides two methods for treating research or experimental expenditures paid or incurred by the taxpayer in connection with his trade or business. These expenditures may be treated as expenses not chargeable to capital account and deducted in the year in which they are paid or incurred (see §1.174-3), or they may be deferred and amortized (see

termination shall not be treated as resulting in a disposition of the partnership's trade or business for purposes of section 195(b)(2). See §1.708-1(b)(6) for rules concerning the treatment of these start-up expenditures by the new partnership. (b) Effective/applicability date. This section applies to a technical termination of a

) Scope. Sections 1.145-0 through 1.145-2 apply for purposes of section 145(a). (c) Effective dates. For effective dates of §§1.145-0 through 1.145-2, see

The term taxable gifts means the “total amount of gifts” made by the donor during the “calendar period” (as defined in §25.2502-1(c)(1)) less the deductions provided for in sections 2521 (as in effect before its repeal by the Tax Reform Act of 1976), 2522, and 2523 (specific exemption, charitable, etc., gifts and the marital

amounts that have actually been transferred to the Fund under §701.9006-1(a). Any amounts in the Primary Account after October 31 following a presidential election will be returned to the Fund for the purpose of making the transfers prescribed by §701.9006-1(c), (d), and (f) for the next

TTB will conduct proceedings for the denial of an application for an operating permit in accordance with the procedures set forth in part 71 of this chapter if the appropriate TTB officer has reason to believe that: (a) The applicant (including, in the case of a corporation, any officer, director, or principal stockholder, and, in the case of a partnership, a partner) is, by reason of business experience, financial standing, or trade

(a) Time and place. The time and place of examination pursuant to the provisions of 26 U.S.C. 7602 must be such time and place as may be fixed by an appropriate TTB officer and as are reasonable under the circumstances. The date fixed for appearance shall not be less than 10 days from the date of the summons.