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(a) Scope. This section provides additional rules for members of a limited affiliated group of organizations, as defined in paragraph (b) of this section (relating generally to organizations that are affiliated solely by reason of provisions of their governing instruments that extend control solely with respect to national legislation). Except as otherwise provided in this section,
This section lists the headings for §§1.904(g)-1 through 1.904(g)-3.
§1.904(g)-1 Overall domestic loss and the overall domestic loss account
decedent under the plan is excludable from the decedent's gross estate under §20.2039-2.
(b) “Lump sum distribution” defined. For purposes of this section the term “lump sum distribution” means a lump sum distribution defined in section 402(e)(4)(A) that satisfies the requirements of section 402(e)(4)(C), relating to the aggregation
) Summonses issued to third-party recordkeepers. A summons issued under section 6420(e)(2), 6421(g)(2), 6427(j)(2), or 7602 for the production of records (or testimony about such records) by a third-party recordkeeper, as described in section 7603(b)(2) and §301.7603-2, may also be served by certified or registered mail to the third-party recordkeeper's last
section 882(a) pursuant to a treaty obligation of the United States.
(2) Indemnity bondAny indemnity bond required to be filed by any person to secure payment of any pension, allowance, allotment, relief, or insurance by the United States, or to secure a duplicate for, or the payment of, any bond, note, certificate of indebtedness, war-saving certificate, warrant or check, issued by the United States.
(a) In generalEvery applicable qualified opportunity zone business shall furnish to the qualified opportunity fund described in subsection (b) a written statement at such time, in such manner, and setting forth such information as the Secretary may by regulations prescribe for purposes of enabling such qualified opportunity fund to meet the requirements of
fiduciary, pursuant to the provisions of section 6012(b)(3), shall be signed by such fiduciary. See paragraph (b)(4) of §1.6012-3.
(3) By agents. A return with respect to income required to be made by an agent for a foreign corporation shall be signed by such agent. See paragraph (g) of
officers.
(2) The use of commercial banks for payment of excise taxes imposed by 26 U.S.C. Subtitles E and F.
(3) The preparing or executing of returns; deposits; payment on notice and demand; assessment; abatements, credits and refunds; limitations on assessment; limitations on credit or refund; periods of limitation in judicial proceedings; interest; additions to tax, additional amounts, and assessable penalties; enforced collection
, the term former partners means, for a partnership that has ceased to exist, the partners of the partnership during the adjustment year (as defined in §301.6241-1(a)(1)) that corresponds to the reviewed year for which the adjustments were made.
(ii) Partnership-partner ceases to exist.
overall foreign loss) in any taxable year in which its gross income from sources without the United States subject to a separate limitation (as defined in §1.904(f)-1(c)(2)) is exceeded by the sum of the deductions properly allocated and apportioned thereto. However, for taxable years prior to 1983, affiliated groups may have determined their overall foreign losses for income subject to the
(a) General rule. In—
(1) Determining under section 852(a) and paragraph (a) of §1.852-1 whether the deduction for dividends paid during the taxable year (without regard to capital gain dividends) by a regulated investment company equals or exceeds 90 percent of its investment company taxable
amortization deduction is claimed;
(ii) The date on which such facility was completed or acquired (see paragraph (b)(2)(iii) of §1.169-2);
(iii) The period referred to in paragraph (a)(6) of §1.169-2 for the facility as of the date the
guidance on making effective comments, please visit https://www.epa.gov/dockets/commenting-epa-dockets.
II. Background
The WIPP was authorized in 1980, under section 213 of the DOE National Security and Military Applications of Nuclear Energy Authorization Act of 1980 (Pub. L. 96-164, 93 Stat. 1259, 1265), “for the express purpose of providing a research and development facility to
(a) Nature of election. In lieu of determining the increase for a taxable year of a foreign corporation beginning before January 1, 1976, under the provisions of section 954(f) and paragraph (a) of §1.954-5, or the decrease under the provisions of section 955(a)(2) and paragraph (b) of
) of this section and §1.565-2 for the rules as to when all or a portion of the amount so specified will be disregarded for tax purposes.
(3) A consent may be filed at any time not later than the due date (including extensions) of the corporation's income tax return for the taxable year for which the dividends paid deduction is claimed. With such return, and not