(A) In generalThe term "expatriated entity" means— (i) the domestic corporation or partnership referred to in subparagraph (B)(i) with respect to which a foreign corporation is a surrogate foreign corporation, and (ii) any United States person who is related (within the meaning of

(a) Administrative review (1) Administrative review (A) Prior approval requiredNo assessment may be made under section 6851(a), 6852(a), 6861(a), or 6862, and no levy may be made under

section generally, substituting "(within the meaning of subchapter B)" for "in the amount determined under section 2602". Statutory Notes and Related Subsidiaries Effective Date of 1986

(a) OffensesAny person who— (1) Unregistered stillshas in his possession or custody, or under his control, any still or distilling apparatus set up which is not registered, as required by section 5179(a); or (2) Failure to file application

section 4121 or subchapter B of chapter 42. (2) Certain repaid amounts, etc.The following amounts shall be credited to the Black Lung Disability Trust Fund: (A) Amounts repaid or recovered under subsection (b) of section 424 of the Black

§1.684-1(a). The trust must also comply with the rules of section 6048. (b) Date of transfer. The transfer described in this section shall be deemed to occur immediately before, but on the same date that, the trust meets the definition of a foreign trust set forth in section 7701(a)(31)(B). (c)

statutory language of title I of ERISA. (c) A group health plan that is subject to section 4980B (or the parallel provisions under ERISA) is referred to as being subject to COBRA. (See Q&A-4 of §54.4980B-2). A qualified beneficiary can be required to pay for COBRA continuation coverage. The term qualified beneficiary is defined

In the case of any tax properly deducted and withheld under section 1471 from a specified financial institution payment— (i) if the foreign financial institution referred to in subparagraph (B) with respect to such payment is entitled to a reduced rate of tax with respect to such payment by reason of any treaty obligation of the United States—

(a) Failures to pay (1) Premiums for eligible beneficiariesThere is hereby imposed a penalty on the failure of any assigned operator to pay any premium required to be paid under section 9704 with respect to any eligible beneficiary. (2

; or (B) which, after removal without payment of tax pursuant to section 5704, have been diverted from the applicable purpose or use specified in that section; or (2) with intent to defraud the United States, purchase, receive, possess, offer for sale, or sell or otherwise dispose of, after removal, any tobacco products or

member's taxable income, except to the extent that expenses, losses, and other deductions are allocated and apportioned as if all domestic members of an affiliated group were a single corporation under section 864(e) and the regulations thereunder. See §1.861-9T through §1.861-11T for rules regarding

section 993(f)) of such corporation consist of qualified export receipts (as defined in section 993(a)), (B) the adjusted basis of the qualified export assets (as defined in section 993(b)) of the

form such that there are at least three copies of the form. One copy of the certificate shall be retained by the issuer; one copy shall be retained by the lender; and one copy shall be forwarded to the State official who issued the certification required by §1.25-4T(d), unless that State official has stated in writing that he does not want to receive such copies. (b

This section lists the major paragraphs contained in §§1.679-1 through 1.679-7 as follows: §1.679-1   U.S. transferor treated as owner of foreign trust.

(a)-(c) [Reserved]. For further guidance, see §1.861-14T(a) through (c). (d) Definition of affiliated group—(1) General rule. For purposes of this section, the term affiliated group has the same meaning as is given

section 6072 and §§1.6072-1 to 1.6072-4, inclusive. For provisions relating to the place for filing income tax returns, see section 6091 and §§1.6091-1 to 1.6091-4, inclusive. (b) (1) Returns on which tax

administration or enforcement of this part by TTB Order 1135.46, Delegation of the Administrator's Authorities in 27 CFR 46, Miscellaneous Regulations Relating to Tobacco Products and Cigarette Papers and Tubes. (b) Articles subject to floor stocks tax. All Federally taxpaid or tax determined tobacco products (other than large cigars described in

For purposes of this section, the term "2-percent shareholder" means any person who owns (or is considered as owning within the meaning of section 318) on any day during the taxable year of the S corporation more than 2 percent of the outstanding stock of such corporation or stock possessing more than 2 percent of the total combined voting power of all stock of such corporation.

(a) ReportsThe operator of a boat on which one or more individuals, during a calendar year, perform services described in section 3121(b)(20) shall submit to the Secretary (at such time, and in such manner and form, as the Secretary shall by regulations prescribe) information respecting— (1) the