Applicable percentage—(i) In general. Except as provided in this paragraph (a)(2), in the case of a foreign partner that is a corporation for U.S. tax purposes, the applicable percentage is the highest rate of tax specified in section 11(b)(1) for such taxable year. Except as provided in this paragraph (a)(2) and §1.1446-5, in the case of a foreign

not subject to the provisions of this section and §§1.467-2 through 1.467-9 (the section 467 regulations), if it specifies equal amounts of rent for each month throughout the lease term and all payments of rent are due in the calendar year to which the rent relates (or in the preceding or succeeding calendar year). In addition, the section 467 regulations do not apply to a rental agreement that

(a) Original issue discount included in income on basis of constant interest rate (1) General ruleFor purposes of this title, there shall be included in the gross income of the holder of any debt instrument having original issue discount, an amount equal to the sum of the daily portions of the original issue discount for each day during the taxable year on which such holder held

For further rules applicable to consolidated groups, see §1.1502-78. For further rules applicable to consolidated groups that include insolvent financial institutions, see §301.6402-7 of this chapter. [T.D. 8446, 57 FR

§ 101-26.100 Scope of subpart. This subpart provides policy guidance of a general nature concerning procurement of lowest cost items obtainable from GSA supply sources; availability from GSA of special buying services in addition to the specified GSA procurement sources; criteria for placing end-of-year

stock of such corporation from any shareholder if— (1) such shareholder held such stock (as determined under section 1223) for less than 2 years before entering into the agreement to make the transfer, (2) at some time during the 2-year period ending on the date of such acquisition— (A) such

Fee categories. There are four categories of FOIA requesters for fee purposes: “commercial use” requesters, “educational and non-commercial scientific institution” requesters, “representatives of the news media” requesters, and “all other” requesters. The categories are defined in §1800.2, and applicable fees, which are the same in two of the categories, will be

distribution or transaction that is part of the same distribution, except for— (A) The increase required under section 737(c)(1) for the gain recognized by the partner under section 737; and (B) The decrease required under section 733(2) for any property distributed to the partner other than property previously contributed to the partnership by the distributee partner. See

§1.263A-11(d)) is added to the basis of the designated property rather than the bases of the assets used to produce the designated property. Interest capitalized with respect to designated property that includes both components subject to an allowance for depreciation or depletion and components not subject to an allowance for depreciation or depletion is ratably allocated among, and is treated as a cost of, components that are subject to an allowance for depreciation or depletion.

latest edition of the NFPA 2001 Standard for Clean Agent Fire Extinguishing Systems. Use of this agent should be in accordance with the safety guidelines in the latest edition of the NFPA 2001 Standard for Clean Agent Fire Systems.Users should observe the limitations on HFC-236fa acceptability by taking the following measures:(i) conduct an evaluation of foreseeable conditions of end-use;(ii) determine that the physical or chemical properties, or