(a) In general. [Reserved] (b) Attribution from corporations, partnerships, estates and trusts. (1) [Reserved]. (2) Limitation. Section 1.382-2T(h)(2)(i

corporation will succeed to the tax attributes described in section 381(c). Furthermore, sections 269 and 482 apply for any consolidated return year. However, in a recognition transaction otherwise subject to section 1001, for example, the rules of section 1001 continue to apply, but may be modified by the intercompany transaction regulations under §1.1502-13. (2)

with respect to an automatic contribution arrangement described in paragraph §1.401(k)-3(j) that satisfies the safe harbor requirements of §1.401(k)-3, the limitations on matching contributions of paragraph (d) of this section, the notice requirement of paragraph (e) of this section, the

(a) General rule. This section applies to certain losses and deductions from the sale, exchange, or other transfer of property between corporations that are members of a consolidated group or a controlled group (an intercompany transaction). See section 267(f) (controlled groups) and §1.1502-13 (consolidated groups) for

Scope. Sections 1.144-0 through 1.144-2 apply for purposes of the rules for small issue bonds under section 144(a) and qualified redevelopment bonds under section 144(c), except that §1.144-2 does not apply to the requirements for qualified small issue bonds under section 144(a)(4) (relating to

deferred benefits to employees, their spouses, or their dependents. See section 404(b) and §1.404(b)-1T. Section 404 (a) and (d) requires that such a contribution or compensation be paid or incurred for purposes of section 162 or 212 and satisfy the requirements for deductibility under either of those sections. However, notwithstanding the above, section 404 does not apply to contributions paid

(a) In general. A separate line of business (as determined under §1.414(r)-3) that does not satisfy any of the safe harbors in §1.414(r)-5 for a testing year nonetheless satisfies the administrative scrutiny

(a) General effective date. Except as otherwise provided in this section, §§1.457-1 through 1.457-11 apply for taxable years beginning after December 31, 2001. (b) Transition period for eligible plans to comply with EGTRRA. For taxable years beginning after

(b) Is denied exemption under the provisions of section 501(h) (see §1.501(h)-3 or §56.4911-9). This section does not apply, however, to an organization that was described in section 501(h)(5) and

(a) If an accumulation distribution is deemed under §1.666(a)-1A to be distributed on the last day of a preceding taxable year and the amount is not less than the undistributed net income for such preceding taxable year, then an additional amount equal to the “taxes imposed on the trust attributable to the undistributed net income” (as defined in

(a) Amount of foreign currency gain or loss. Foreign currency gain or loss with respect to distributions of section 965(a) previously taxed earnings and profits (as defined in §1.965-1(f)(39)) is determined based on movements in the exchange rate between December 31, 2017, and the time such distributions are made.

The following table of contents is provided to facilitate the use of §§1.1377-1 through 1.1377-3: §1.1377-1 Pro rata share. (a) Computation of pro

This section lists the paragraphs in §§301.9100-1 through 301.9100-3. §301.9100-1 Extensions of time to make elections. (a) Introduction.

evade any tax imposed by provisions of 26 U.S.C. enforced and administered by the Bureau, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time. (c) No return. In the case of a failure to file a return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time after the date prescribed for

(a) In generalIn addition to any other penalty provided by law, any person who refuses to admit entry or refuses to permit any other action by the Secretary authorized by section 4083(d)(1) shall pay a penalty of $1,000 for such refusal. (b) Joint and several liability

"private foundations" in parenthetical. Statutory Notes and Related Subsidiaries Effective Date of 1987 Amendment Amendment by Pub. L. 100–203 applicable to taxable years beginning after Dec. 22, 1987, see

(a) General ruleExcept as provided in subsection (b), if property is transferred to a trust in exchange for an interest in other trust property and if the trust would be an investment company (within the meaning of section 351) if it were a corporation, then gain shall be recognized to the transferor.