Section 1.1445-2 provides for various situations in which withholding is not required under section 1445(a). Section 1.1445-3 provides for adjustments to the amount required to be withheld by transferees under section 1445(a). Section 1.1445-4 prescribes the duties of agents in transactions subject

paid or incurred by an S corporation is made by the S corporation. In the case of qualified capital costs paid or incurred by the members of a consolidated group (within the meaning of §1.1502-1(h)), the section 179B election with respect to such costs is made for each member by the common parent of the group. (B)

includes a controlled group of corporations, as defined in 26 U.S.C. 1563, and implementing regulations in 26 CFR §§1.563-1 through 1.1563-4. Also, the rules for a “controlled group of corporations” apply in a similar fashion to groups which include partnerships and/or sole proprietorships. If one entity maintains more than 50% control over a group consisting of corporations and one, or more, partnerships

(4) Debt-for-debt exchange—(i) Rule. A debt instrument issued in a debt-for-debt exchange, including a deemed exchange under §1.1001-3, will not be treated as the subject of a recent sales transaction for purposes of section 1274(b)(3)(B)(ii)(I) even if the debt instrument exchanged for the newly issued

§1.1402(f)-1. (b) Computation of gross income. For purposes of this section gross income has the following meanings: (1) In the case of any such trade or business in which the income is computed under a cash receipts and disbursements method, the gross receipts from such trade or business reduced by the cost

26 U.S.C. 408A) or similar provisions of law applicable to a U.S. territory or possession; and (iii) Any plan described in section 401(d) (Keogh account) of the Internal Revenue Code (26 U.S.C. 401(d)) or similar provisions of law applicable to a U.S. territory or possession. (2) Insurance coverage for the

(a) In generalIn a two-party exchange, the delivering person shall not be liable for the tax imposed under section 4081(a)(1)(A)(ii). (b) Two-party exchangeThe term "two-party exchange" means a transaction, other than a sale, in which taxable fuel is transferred from a delivering

that terminal operators provide a notice with respect to dyed fuel, see §48.4101-1(h)(3) (relating to terms and conditions of registration for terminal operators). (c) Effective date. This section is applicable with respect to diesel fuel after December 31, 1993, and with respect to kerosene after June 30, 1998.

“excess aggregate contribution” has the meaning set forth in §1.401(m)-5 of this chapter. For purposes of determining excess aggregate contributions under an annuity contract described in section 403(b), the contract is treated as a plan described in section 401(a). (2) Excess contributions. The term “excess contributions

considerations (A) Financial disclosureDuring the entire period that an individual appointed under subparagraph (A) or (D) of paragraph (1) is a member of the Oversight Board, such individual shall be treated as serving as an officer or employee referred to in section 13103(f) of title 5, United States Code, for purposes of subchapter I of chapter 131

treated as held by S corporation. (c) Straight debt safe harbor. (d) Examples. §1.1361-3   QSub election. (a) Time and manner of making election. (1) In general. (2) Manner of making election. (3) Time of making election. (4) Effective date of election. (5) Example. (6) Extension of time for making a QSub

–34 substituted "section 751(d)" for "section 751(d)(2)". 1996—Subsec. (d)(3)(B). Pub. L. 104–188 substituted "Subparagraph" for "Subparagaph". Statutory Notes and Related