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this section. (2) Passive activity loss. Rules relating to the computation of the passive activity loss for the taxable year are contained in §1.469-2T. (3) Passive activity credit. Rules relating to the computation of the passive activity credit for the
(a) Qualifying shipping activitiesFor purposes of this subchapter, the term "qualifying shipping activities" means— (1) core qualifying activities, (2) qualifying secondary activities, and (3) qualifying incidental activities. (b) Core qualifying activitiesFor purposes of this
Editorial Notes Prior Provisions For prior section 4461, see Prior Provisions note set out preceding
(ii) The first day of the month in which the claimant becomes eligible for a child annuity as explained in part 216 of this chapter. (2) Child age annuity. The earliest date permitted by law is the later of— (i) The month shown in paragraph (b)(1) of this section; or (ii) The first day of the sixth month before the
Regulations Regarding “Like Kind” Although the TCJA removed personal and certain intangible property from eligibility for like-kind exchange treatment, the need to determine whether the relinquished real property and the replacement real property are of a like kind continues to exist after the changes to section 1031 made by the TCJA. Current
lesser of— (i) $40,000 (adjusted pursuant to section 415(d) and §1.415(d)-1(b)); or (ii) 100 percent of the participant's compensation (as defined in §1.415(c)-2) for the limitation year.
(a) General rule. If the Secretary or his delegate determines pursuant to paragraph (c) of §301.6363-1 that a State did not file a valid notice of election or does not have a tax which would meet the requirements for qualification specified in section 6362 and the regulations thereunder if a State agreement were in effect with
(a) Application of separate levy rules as applied to dual capacity taxpayers—(1) In general. If the application of a foreign levy (as defined in §1.901-2(g)(3)) is different, either by the terms of the levy or in practice, for dual capacity taxpayers (as defined in
642(h)(1), there will be allowable to A a capital loss carryover of $2,500 for his taxable year 1954 and for his next 4 taxable years in accordance with paragraph (a) of §1.1212-1. There will be allowable to the trust a similar capital loss carryover of $2,500 for its taxable year ending August 31, 1955, and its next 4 taxable years (but see paragraph (b) of
examples 1, (2), and (3) of paragraph (b)(3)(iii) of §1.514(b)-1 for illustrations of proper allocation. [T.D. 7229, 37 FR 28153, Dec. 21, 1972]
In order to constitute a reasonable attempt to notify the debtor, OPM must have used a mailing address for the debtor obtained from the IRS pursuant to 26 U.S.C. 6103(m)(2) within a period of 1 year preceding the attempt to notify the debtor, unless OPM received clear and concise notification from the debtor that notices from the agency are to be sent to an address different from the
The regulations of this part apply to certifications by the Administrator of water or air pollution control facilities for purposes of section 169 of the Internal Revenue Code of 1954, as amended, 26 U.S.C. 169, as to which the amortization period began after December 31, 1975. Certification of air or water pollution control facilities as to which the amortization period
Every bank (as defined in section 581) maintaining a common trust fund shall make a return for each taxable year, stating specifically, with respect to such fund, the items of gross income and the deductions allowed by subtitle A, and shall include in the return the names and addresses of the participants who would be entitled to share in the taxable
(a) In general. Any person applying to a district director for a determination described in paragraph (b)(7) of §1.7476-1 shall cause notice of the application to be given to persons who qualify as interested parties under §1.7476-1
is subject to the Federal estate or gift tax within the meaning of §26.2652-1(a)(2). See §26.2612-1(a) for the definition of direct skip. (2) Taxable distributions and taxable terminations. Chapter 13 applies to a taxable
(a) In general. For purposes of §§1.354-1(e), 1.355-1(c), and 1.356-3(b), the terms stock and securities do not include— (1) Nonqualified preferred stock, as defined in section 351(g)(2), received in exchange for (or in
instrument is the amount paid for the instrument. For example, in the case of a debt instrument evidencing a loan to a natural person, the issue price of the instrument is the amount loaned. See §1.1275-2(d) for rules regarding Treasury securities. For purposes of this paragraph (a), money includes functional currency and, in certain circumstances, nonfunctional currency. See
(a) General rule. A separate line of business is a line of business (as determined under §1.414(r)-2) that is organized and operated separately from the remainder of the employer. Paragraph (b) of this section sets forth the rules for determining whether a line of business is organized and operated separately from the