(a) In general. For purposes of paragraph (b)(2)(ii)(d) of §1.1563-1, a member of a controlled group of corporations shall be considered to be a franchised corporation for a taxable year if each of the following conditions is satisfied for one-half (or more) of the number of days preceding

authorizations of, practitionersNot later than 6 months after the date of the enactment of this subparagraph, the Secretary shall publish guidance to establish uniform standards and procedures for the acceptance of taxpayers' signatures appearing in electronic form with respect to any request for disclosure of a taxpayer's return or return information under section 6103(c) to a practitioner or any

(a) Definition of qualified mortgage credit certificate. For purposes of §§1.25-1T through 1.25-8T, the term “qualified mortgage credit certificate” means a certificate that meets all of the requirements of this section. (b) Qualified mortgage credit certificate

sales subject to §§1.863-1 through 1.863-3. Paragraph (h) of this section provides effective dates for the rules in this section. (2) Rules of application for Section 863 Sales. Once a taxpayer has elected a method described in paragraph (b) of this section, the taxpayer must separately apply that method to Section 863 Sales in

to be reimbursed for amounts advanced to a REMIC pursuant to the terms of a credit enhancement contract (as defined in §1.860G-2 (c)(2)) is not an interest in the REMIC even if the credit enhancer is entitled to receive interest on the amounts advanced. (iv) Rights to acquire mortgages. The right to acquire or 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) WIN expenses—(1) In general. Except as otherwise provided in paragraphs (b) through (g) of this section, for purposes of §§1.50A-1 through 1.50B-5, the term “work incentive program expenses” (referred to in

the amount of any deduction allowable to the taxpayer for interest paid or accrued during such taxable year. (2) Amount of interestThe amount of interest determined under this paragraph with respect to a prior taxable year is the amount of interest which would have been imposed under section 6601 on the underpayment of tax for such year which would

(a) In general. For purposes of section 956(a) and §1.956-1, the term “United States property” also includes any trade or service receivable if the trade or service receivable is acquired (directly or indirectly) from a related person who is a United States person (as defined in section 7701(a)(30)) (a

in the deemed asset sale. The amount of old target's tax reserves is the amount that is properly taken into account by old target for the contracts at the close of the taxable year that includes the deemed sale tax consequences (before giving effect to the deemed asset sale and assumption reinsurance transaction). Old target's tax reserves are a liability of old target taken into account in determining ADSP under

(a) Statements required from payor. Every payor of any reportable payment (as defined in section 3406(b)(1)) who is required to deduct and withhold tax under section 3406 must furnish to the payee a written statement containing the information required by paragraph (c) of this section. (b) Prescribed form. The prescribed form for the statement required by

(2) whether such assignment is revocable. (e) Prohibition on deductionNotwithstanding section 247, no deduction shall be allowed to a Native Corporation for purposes of any amounts described in subsection (a). (f) DefinitionsFor purposes of this section, the terms "Native Corporation

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]

) For temporary emergency needs exceeding three months and approved in writing by the DPMO; or (4) For temporary emergency needs of three months or less in lieu of commercial rentals. These transfers will not count toward the allocation. {"origins":[{"level":"part","identifier":"109-26","label_level":"Part 109-26","hierarchy":{"title":"41","subtitle":"C","chapter":"109","subchapter":"A

true and correct. (d) As State B, when you receive from an applicant firm all the information required by paragraph (c) of this section, you must take the following actions: (1) Within seven days contact State A and request a copy of the site visit review report for the firm (see §26.83(c)(1)), any

(2) the basis of the distributee in such property shall be its fair market value. (d) Coordination with wash sale rulesFor purposes of section 1091— (1) any residual interest in a REMIC shall be treated as a security, and (2) in applying such section to any loss

or wages for work performed or that has control over employee opportunities, except for the Federal Government or any State or foreign government. For the purposes of this regulation, VETS will recognize employers based on the Employer Identification Number, as described in 26 CFR 301.7701-12, used to furnish an IRS Form W-2 to an employee. However, in the case of an agent designated pursuant to 26 CFR 31.3504-1, a payor designated pursuant to 26 CFR 31.3504-2, or a Certified Professional

(a) General. The proprietor may temporarily extend or curtail the distilled spirits plant premises to allow for several other types of alternate uses. Premises may be alternately curtailed or extended to allow bonded premises to be used temporarily as general premises, or to allow general premises to be used as bonded premises. A curtailment or extension of distilled spirits plant premises may also allow for the use of the

, or duration of the copyright for the original term." Statutory Notes and Related Subsidiaries Effective Date of 1992 Amendment Amendment by Pub. L. 102–307 effective June 26, 1992, but applicable only to copyrights secured between January 1, 1964, and December

-percent shareholders. (A) Related persons. (B) Investment companies. (4) Anti-abuse rule. (5) Example. (e) Substantiation that a foreign corporation is publicly traded. (1) General rule. (2) Availability and retention of documents for inspection. (f) Reporting requirements. §1.883-3   Treatment of controlled foreign

A State tax meets the additional requirements of section 6362(f) and this section only if: (a) State agreement must be in effect for period concerned. A State agreement, as defined in paragraph (a) of §301.6361-4, is in effect with respect to such tax for the taxable period in question.

Every manufacturer of tobacco products or cigarette papers or tubes in the United States who receives, under its bond without payment of internal revenue tax, Puerto Rican tobacco products or cigarette papers or tubes not put up in packages, and who subsequently removes such products subject to tax, must pay the tax imposed on these products by 26 U.S.C. 7652(a) at the