in which the corporation, trust, or association maintains its principal place of business or principal office or agency, that its failure to be a qualified real estate investment trust for the taxable year in question was due to reasonable cause and not due to willful neglect. The principles of §1.856-7(c) (including the principles relating to expert advice) will apply in determining whether, for

(a) Taxable transfers (1) General ruleA tax, computed as provided in section 2502, is hereby imposed for each calendar year on the transfer of property by gift during such calendar year by any individual resident or nonresident. (2) Transfers of

(a) through (b)(1) [Reserved]. For further guidance, see §1.367(a)-6T(a) through (b)(1). (b) (2) No active conduct exception. The rules of this paragraph (b) apply regardless of whether any of the assets of the foreign branch satisfy the active trade or

), the corporate income tax imposed by section 11(a) or 1201(a). The method provided by section 860 is to allow an additional deduction for a dividend distribution (that meets the requirements of section 860 and §1.860-2) in computing the deduction for dividends paid for the taxable year for which the deficiency is determined. A deficiency divided may be an ordinary dividend or, subject to the

this chapter (Payment by check or money order) and which is acceptable to that officer. In paying the tax, a fractional part of a cent shall be disregarded unless it amounts to one-half cent or more, in which case it shall be increased to one cent. (Aug. 16, 1954, Ch. 736, 68A Stat. 778 (26 U.S.C. 6313) Aug. 16, 1954, ch. 736, 68A Stat. 775 (

(a) Overview—(1) Scope of §§1.960-1 through 1.960-3. This section and §§1.960-2 and 1.960-3 provide rules to associate foreign income taxes of a controlled foreign corporation with the income that a domestic corporation that is a United States shareholder of the controlled foreign corporation

(a) In general. Section 4943 and §§53.4943-1 through 53.4943-11 shall take effect for taxable years beginning after December 31, 1969, except as otherwise provided by such sections. (b) Special transitional rule. In the case of any acquisition of excess

property so transferred, over (2) the adjusted basis (for purposes of determining gain) of such property in the hands of the transferor. (b) ExceptionSubsection (a) shall not apply to a transfer to a trust by a United States person to the extent that any person is treated as the owner of such trust under section 671.

26 U.S.C. 381(c)(23), 381(c)(24)) 85 Stat. 557 (26 U.S.C. 381(c)(24)), 7805, 68A Stat. 917 (26 U.S.C. 7805)) [T.D. 7289, 38 FR 30557, Nov. 6, 1973]

Personal property may be seized by the Commissioner of Internal Revenue or his delegate for forfeiture to the United States when involved, used, or intended to be used, in violation of the internal revenue laws, other than chapters 51 (distilled spirits), 52 (tobacco) and 53 (firearms) of the I.R.C. (Sec. 7321, 68A Stat. 869; 26 U.S.C. 7321.)

After gauging, the proprietor must determine the tax on the spirits to be removed from the bonded premises. The proprietor must use the tax rate prescribed in 26 U.S.C. 5001 to calculate the tax, unless the product is eligible for a reduced effective tax rate as provided in 26

No person who sells, or offers for sale, distilled spirits, or agent or employee of such person, shall: (a) Place in any liquor bottle any distilled spirits whatsoever other than those contained in that bottle at the time of closing under the provisions of 26 U.S.C. chapter 51; or (b) By the addition

(a) Overview of regulations. This section provides rules for determining a taxpayer's separate limitation losses, for establishing separate limitation loss accounts, and for making additions to and reducing such accounts for purposes of section 904(f). Section 1.904(f)-8 provides rules for recharacterizing the balance in

) Distributions of partnership interests treated as exchangesExcept as otherwise provided in regulations, for purposes of— (1) section 708 (relating to continuation of partnership), (2) section 743 (relating to optional adjustment to basis

(a) Definitions. The following definitions apply for purposes of this section and §§1.6050Y-2 through 1.6050Y-4: (1) Acquirer. The term acquirer means any person that acquires an interest in a life insurance contract

be allowed as a credit against the tax imposed by this subchapter an amount equal to the tax (if any) imposed by section 4071 on such tires. Editorial Notes

) Target corporationThe term "target corporation" means any corporation the stock of which is acquired by another corporation in a qualified stock purchase. (3) Qualified stock purchaseThe term "qualified stock purchase" means any transaction or series of transactions in which stock (meeting the requirements of section 1504(a)(2)) of 1

(a) In generalIn addition to the credit allowed under section 6428, in the case of an eligible individual, there shall be allowed as a credit against the tax imposed by subtitle A for the first taxable year beginning in 2020 an amount equal to the sum of— (1) $600 ($1,200 in the case of eligible