(a) General ruleA regulated investment company— (1) which holds (directly or indirectly) one or more tax credit bonds on one or more applicable dates during the taxable year, and (2) which meets the requirements of section 852(a) for the taxable year (determined

(a) Creation of Trust FundThere is established in the Treasury of the United States a trust fund to be known as the "Vaccine Injury Compensation Trust Fund", consisting of such amounts as may be appropriated or credited to such Trust Fund as provided in this section or section 9602(b). (b

advance amountFor purposes of this section— (1) In generalExcept as otherwise provided in this subsection, the term "annual advance amount" means, with respect to any taxpayer for any calendar year, the amount (if any) which is estimated by the Secretary as being equal to 50 percent of the amount which would be treated as allowed under subpart C of part IV of subchapter A of chapter 1 by reason of

(1) EntityIn the case of a tax-exempt entity— (A) In generalExcept as provided in subparagraph (B), the amount of the tax imposed under subsection (a)(1) with respect to any transaction for a taxable year shall be an amount equal to the product of the highest rate of tax under section 11, and the greater of

the Secretary, make a return setting forth the aggregate amount of such payments, and the name and address of the person to whom paid. (b) Dividend defined (1) General ruleFor purposes of this section, the term "dividend" means— (A) any distribution by a corporation which is a dividend (as defined in

for accounts subject to backup withholding under section 3406(a)(1) (B) or (C) where the names are switched. See §31.3406(d)-5(c)(4)(iii) under which a payor may withhold under section 3406(a)(1)(B) as required even though the names or taxpayer identification numbers on the account have been switched. The rules under

such sale may bring a civil action against the United States in a district court of the United States. (3) Substituted sale proceedsIf property has been sold pursuant to an agreement described in section 6325(b)(3) (relating to substitution of proceeds of sale), any person who claims to be legally entitled to all or any part of the amount held as a

) for any year are more than de minimis, subparagraph (A) shall be applied by substituting "$15,000" for "$2,500" with respect to such person. (C) Exception for church plansThis paragraph shall not apply to any failure under a church plan (as defined in section 414(e)). (c) Limitations on amount of tax

(a) Reports by employeesEvery employee who, in the course of his employment by an employer, receives in any calendar month tips which are wages (as defined in section 3121(a) or section 3401(a)) or which are compensation (as defined in

the purchasing corporation and the sellers of the stock. (Rules concerning eligibility for these elections are contained in §§1.338-2, 1.338-3, and 1.338(h)(10)-1.) However, if, as a result of the deemed purchase of old target's assets pursuant to a section 336(e) election, there would be both a qualified stock purchase and a qualified stock disposition (as defined in

1982—Subsec. (c). Pub. L. 97–362, §106(c)(2), struck out provision that the chief judge may assign proceedings under sections 6226, 6228(a), 7428, 7463, 7476, 7477, and 7478 to be heard by the commissioners of the court, and that the court may authorize a commissioner to make the decision of the court with respect to such proceedings, subject to such conditions and review

hire, the term "value" means the actual charge paid for such service or the prevailing charge for comparable service if no actual charge is paid. (b) Special rule for Alaska, Hawaii, and possessions (1) In generalNo tax shall be imposed under section 4461(a) with respect to—

(a) Allocation and apportionment of taxes to a separate category or categories of income—(1) In general—(i) Taxes related to a separate category of income. The amount of foreign taxes paid or accrued with respect to a separate category (as defined in §1.904

(a) In general. If a QBU begins to use the dollar approximate separate transactions method of accounting set forth in §1.985-3 (DASTM) in a taxable year beginning after April 6, 1998, adjustments shall be made as provided by this section. For the rules with respect to foreign corporations, see paragraph (b) of this section. For

income under subsection (a)(1) with respect to such stock for any prior taxable year but for section 1291. In the case of a regulated investment company which elected to mark to market the stock held by such company as of the last day of the taxable year preceding such company's first taxable year for which such company elects the application of this section, the amount referred to in paragraph (1) shall

"applicable financial statement" means, with respect to any taxable year, an applicable financial statement (as defined in section 451(b)(3) or as specified by the Secretary in regulations or other guidance) which covers such taxable year. (c) General adjustments (1) Statements covering different taxable years

(a) Liability for tax (1) Original liabilityThe manufacturer or importer of tobacco products and cigarette papers and tubes shall be liable for the taxes imposed thereon by section 5701. (2) Transfer of liabilityWhen tobacco products

inclusion year the member's GILTI inclusion amount, if any, for the U.S. shareholder inclusion year. See section 951A(a) and §1.951A-1(b). The GILTI inclusion amount of a member for a U.S. shareholder inclusion year is the excess (if any) of the member's net CFC tested income for the U.S. shareholder inclusion year, over the member's net deemed tangible income return for the U.S. shareholder inclusion

profits of such corporation attributable to such stock under §1.1248-2 or 1.1248-3, whichever is applicable, which were accumulated in taxable years of such foreign corporation beginning after December 31, 1962, during the period or periods such stock was held (or was considered as held by reason of the application of section 1223, taking into account

(a) Allowance of marital deductionFor purposes of the tax imposed by section 2001, the value of the taxable estate shall, except as limited by subsection (b), be determined by deducting from the value of the gross estate an amount equal to the value of any interest in property which passes or has passed from the decedent to his

(a) For rules regarding the election of the repair allowance authorized by section 263(f), the definition of repair allowance property, and the conditions under which an election may be made, see paragraphs (d) (2) and (f) of §1.167(a)-11. An election may be made under this section for a taxable year only if the taxpayer makes an election under

Section 457 provides rules for nonqualified deferred compensation plans established by eligible employers as defined under §1.457-2(d). Eligible employers can establish either deferred compensation plans that are eligible plans and that meet the requirements of section 457(b) and

(a) In general. The provisions of §53.6001-1 shall apply to any person subject to tax under chapter 41, subtitle D, of the Code, by treating each reference to chapter 42 in §53.6001-1 as a reference to chapter 41.

The following rules apply in determining the number and size of employers, as required by the MSP provisions for the aged and disabled: (a) All employers that are treated as a single employer under subsection (a) or (b) of section 52 of the Internal Revenue Code (IRC) of 1986 (26 U.S.C. 52 (a) and (b)) are treated as a single employer.

the filing of claim for refund for the taxable year to which the overpayment relates. (The reporting requirements of this section were approved by the Office of Management and Budget under control number 1545-0045) (Sec. 7805, 68A Stat. 917; 26 U.S.C. 7805; sec. 860(e) (92 Stat. 2849,

The proprietor will incur a tax liability greater than the internal revenue tax imposed by 26 U.S.C. 5001(a)(1), if spirits originally imported for nonbeverage purposes are transferred from customs custody to TTB bonded premises pursuant to 26 U.S.C. 5232, and the

(a) Payments for failure to maintain minimum essential health coverage. Any payments or assessments imposed on an individual or individuals pursuant to 26 U.S.C. 5000A(b) as a result of any failure to maintain minimum essential coverage as required by

includible in gross income) shall be included in gross income for the taxable year following the taxable year in which the contract was completed. For purposes of subtitle F (other than sections 6654 and 6655), any interest required to be paid by the taxpayer under subparagraph (B) shall be treated as an increase in the tax imposed by this chapter for the taxable year in which the contract is completed (or

buying member (B). (2) Application of consolidated return principles. Under this section, S's loss or deduction from an intercompany sale is taken into account under the timing principles of §1.1502-13 (intercompany transactions between members of a consolidated group), treating the