acquired L's stock on October 1, 1992, no individual or entity owned, directly or indirectly, five percent or more of the stock of L. As a result, all shareholders were aggregated into a public group and L was considered to be owned by a single 5-percent shareholder (“Public L”) in accordance with §1.382-2T (g)(1) and (j)(1). (iii) Under paragraph (a)(1)(i) of this section, the members of the

This section contains a listing of the headings of §§1.401 (a)(26)-1 through 1.401(a)(26)-9. §1.401(a)(26)-1   Minimum participation requirements (a) General rule. (b) Exceptions to section 401(a)(26). (1) Plans that do not benefit any highly compensated employees. (2) Multiemployer plans. (i) In general.

This section lists the major captions contained in §§1.1254-1 through 1.1254-6. §1.1254-1 Treatment of gain from disposition of natural resource recapture

(a) In general. If a specified person fails to file a Form 8938, “Statement of Specified Foreign Financial Assets,” that includes the information required by section 6038D(c) and §1.6038D-4 with respect to any taxable year at the time and in the manner described in section 6038D(a) and

Related Subsidiaries Effective Date of 2015 Amendment Amendment by Pub. L. 114–41 applicable to returns for taxable years beginning after Dec. 31, 2015, with special rule for certain C corporations, see section 2006(a)(3) of Pub. L. 114–41, set out as a note under

collected in the same manner as if such underpayment were on account of a mathematical or clerical error appearing on the partner's return. Paragraph (2) of section 6213(b) shall not apply to any assessment of an underpayment referred to in the preceding sentence. (c) Exception for notification of inconsistent treatment

return, or (2) uses any such information for any purpose other than to prepare, or assist in preparing, any such return, shall be guilty of a misdemeanor, and, upon conviction thereof, shall be fined not more than $1,000 ($100,000 in the case of a disclosure or use to which section 6713(b) applies), or imprisoned not more than 1 year

Editorial Notes Amendments 1986—Pub. L. 99–514 substituted "$100,000" for "$2,500" in section catchline, introductory provisions, and par. (2), and substituted "$2,500" for "$250" in par. (3). 1976

d. Definitions and Special Rules 8. Furnishing of Withholding Allowance Certificates a. Commencement of Employment b

(a) SRLY limitation. Except as provided in paragraph (f) of this section (relating to built-in losses of the common parent) and paragraph (g) of this section (relating to an overlap with section 382), built-in losses are subject to the SRLY limitation under §§1.1502-21(c) and 1.1502-22(c) (including applicable subgroup

circumstances in which the denial or failure to offer constitutes a violation of applicable law (such as the Americans with Disabilities Act, 42 U.S.C. 12101-12213, the special enrollment rules of section 9801, or the requirements of section 9802 prohibiting discrimination in eligibility to enroll in a group health plan based on health status), then, for purposes of

Section 174 provides two methods for treating research or experimental expenditures paid or incurred by the taxpayer in connection with his trade or business. These expenditures may be treated as expenses not chargeable to capital account and deducted in the year in which they are paid or incurred (see §1.174-3), or they may be deferred and amortized (see

(a) In general. If a partnership that has elected to amortize start-up expenditures under section 195(b) and §1.195-1 terminates in a transaction (or a series of transactions) described in section 708(b)(1)(B) or §1.708-1(b)(2), the

) Scope. Sections 1.145-0 through 1.145-2 apply for purposes of section 145(a). (c) Effective dates. For effective dates of §§1.145-0 through 1.145-2, see

included in the deficiency, such notice shall constitute the notification provided for in section 534(b) and paragraph (c) of §1.534-2. Under such circumstances the statement described in section 534(c) and paragraph (d) of §1.534-2 shall instead be included in the taxpayer's petition to the Tax Court, if

(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of §1.897-3. Paragraph (b) of this section would then appear as paragraph (b)(4) of

For rules relating to the withholding tax liability of a partnership or nominee under section 1446, see §§1.1446-1 through 1.1446-7. For interest, penalties, and additions to the tax for failure to timely pay the tax required to be paid under section 1446, see sections 6601, 6651, 6655 (in the case of publicly traded partnerships, see section 6656), 6672, and 7202

(a) General rule. Notwithstanding §20.2001-1(b), §§20.2010-2(d) and 20.2010-3(d) provide additional rules regarding the authority of the Internal Revenue Service to examine any gift or other tax return(s), even if the time

The term taxable gifts means the “total amount of gifts” made by the donor during the “calendar period” (as defined in §25.2502-1(c)(1)) less the deductions provided for in sections 2521 (as in effect before its repeal by the Tax Reform Act of 1976), 2522, and 2523 (specific exemption, charitable, etc., gifts and the marital

(a) In general. The Secretary will deposit amounts into the Presidential Primary Matching Payment Account (Primary Account) only to the extent that there are amounts in the Presidential Election Campaign Fund (Fund) after the transfers prescribed by §701.9006-1(c) and (d). The Secretary will make this deposit promptly from

(a) Operating permits. The applicant must include a list of any trade names used in the operation of the plant with form TTB F 5110.25, Application for Operating Permit Under 26 U.S.C. 5171(d). The applicant must show the operations for which the trade name will be used and identify the offices where the trade name is registered. The

connections, not likely to maintain operations in compliance with 26 U.S.C. chapter 51, or the regulations issued thereunder; (b) The applicant failed to disclose any material information required, or has made a false statement as to any material fact in connection with the application; or (c) The premises where the applicant proposes to

(a) Distilled spirits and wine may be used for the manufacture of flavors or flavoring extracts of a nonbeverage nature as intermediate products to be used exclusively in the manufacture of other distilled spirits products on bonded premises. (b) Nonbeverage products on which drawback will be claimed, as provided in 26 U.S.C. 5111-5114

(b) The proprietor must keep all spirits and fuel alcohol received for redistillation physically separate from each other and from other spirits and fuel alcohol until they are redistilled; (c) Spirits recovered by redistillation will be treated the same as spirits that have not been redistilled; and (d) All provisions of this subpart and

26 U.S.C. 5001(a)(1) on all alcohol contained therein, regardless of the source. Such articles containing only wine and/or beer will be taxed at the rates prescribed by 26 U.S.C. 5041 and/or 5051, respectively. A formula covering the manufacture of each article shall be filed by the manufacturer in accordance with

(a) Time and place. The time and place of examination pursuant to the provisions of 26 U.S.C. 7602 must be such time and place as may be fixed by an appropriate TTB officer and as are reasonable under the circumstances. The date fixed for appearance shall not be less than 10 days from the date of the summons.