liability. For purposes of this section, the adjusted value of a partner's interest in a partnership is the fair market value of that interest increased by the partner's share of partnership liabilities under §§1.752-1 through 1.752-5. (b) Exceptions—(1) In general. Except as provided in paragraph

provides applicability dates. (b) Application of section 901(m) to pre-1987 foreign income taxes. Section 901(m) and §§1.901(m)-1 through 1.901-8 apply to pre-1987 foreign income taxes (as defined in §1.902-1(a)(10)(iii)) of an

manner provided in this section. See section 1504(e) for tax-exempt corporations eligible to file a consolidated return. (2) Applicability of other consolidated return provisions. The provisions of §1.1502-1 through §1.1502-80

) Qualified small business stockThe term "qualified small business stock" has the meaning given such term by section 1202(c). (2) PurchaseA taxpayer shall be treated as having purchased any property if, but for paragraph (3), the unadjusted basis of such property in the hands of the taxpayer would be its cost (within the meaning of

subsection (a) shall be paid by the Secretary to the Trump account with respect to which such eligible child is the account beneficiary. (c) Eligible childFor purposes of this section, the term "eligible child" means a qualifying child (as defined in section 152(c))— (1) who is born after December 31, 2024, and before

(a) Appearance by counselThe Commission is authorized to appear in and defend against any action filed under section 9011, either by attorneys employed in its office or by counsel whom it may appoint without regard to the provisions of title 5, United States Code, governing appointments in the competitive service, and whose

(a) In generalThere shall be imposed a special tax of $500 per year to be paid by each person who is liable for the tax imposed under section 4401 or who is engaged in receiving wagers for or on behalf of any person so liable. (b) Authorized personsSubsection (a) shall be applied by

This document contains proposed amendments to the Income Tax Regulations (26 CFR part 1) under sections 860G, 882, 1001, and 1275 of the Internal Revenue Code (Code). 1. Elimination of IBORs On July 27, 2017, the U.K. Financial Conduct Authority, the U.K. regulator tasked with overseeing the London interbank offered rate (LIBOR), announced that all currency and term variants of

(a) Foreign base company incomeFor purposes of section 952(a)(2), the term "foreign base company income" means for any taxable year the sum of— (1) the foreign personal holding company income for the taxable year (determined under subsection (c) and reduced as provided in subsection (b)(5)),

(a) In generalFor purposes of section 38, in the case of any eligible small employer, the military spouse retirement plan eligibility credit determined under this section for any taxable year is an amount equal to the sum of— (1) $200 with respect to each military spouse who is an employee of such

(a) Burden of proofIn any proceeding involving the issue of whether or not any person is liable for a penalty under section 6700, 6701, or 6702, the burden of proof with respect to such issue shall be on the Secretary. (b) Deficiency procedures not to applySubchapter B of chapter 63