(a) Domestic and foreign business entities. A business entity (including an entity that is disregarded as separate from its owner under §301.7701-2(c)) is domestic if it is created or organized as any type of entity (including, but not limited to, a corporation, unincorporated association, general partnership, limited

This section lists the major paragraphs contained in §§301.7701(i)-1 through 301.7701(i)-4. §301.7701(i)-1   Definition of a taxable

(a) General ruleFor purposes of computing the dividends paid deduction under section 561, in the case of a personal holding company the dividend carryover for any taxable year shall be the dividend carryover to such taxable year, computed as provided in subsection (b), from the two preceding taxable years.

section 2284 of title 28, United States Code, and any appeal shall lie to the Supreme Court. Editorial Notes Amendments 2018—Subsec. (b)(1

act or event will occur is so remote as to be negligible. See paragraph (e) of §1.170A-1. (b) Contributions of certain partial interests in property for which a deduction is allowed. A deduction is allowed under section 170 for a contribution not in trust of a partial interest which is less than the donor's entire interest in

This section lists the captions contained in the regulations under section 706. §1.706-1   Taxable years of partner and partnership. (a) Year in which partnership income is includible. (b) Taxable year. (1) Partnership treated as

that D otherwise meets the requirements under section 937(a) and §1.937-1(b) and (f)(1) (year-of-move exception), D is considered a bona fide resident of American Samoa for 2008. Accordingly, under section 931 and paragraph (a)(1) of this section, D should exclude from his 2008 Federal gross income any income from sources within American Samoa and any income that is effectively connected with the

establishes a business purpose to the satisfaction of the Commissioner under section 442. (b) Adoption of taxable year. An electing S corporation may adopt, in accordance with §1.441-1(c), its required taxable year, a taxable year elected under section 444, or a 52-53-week taxable year ending with reference to its required taxable year

(a) In general. The rules of §1.6038A-7 may be applied with respect to a transaction between a foreign related party and the reporting corporation (including any transaction engaged in by a partnership that is attributed to the reporting corporation under

(a) When excluded from wages. If a reimbursement or other expense allowance arrangement meets the requirements of section 62(c) of the Code and §1.62-2 and the expenses are substantiated within a reasonable period of time, payments made under the arrangement that do not exceed the substantiated expenses are treated as paid under an

(a) In general. A claim for credit or payment described in §48.6420-1 with respect to gasoline used after June 30, 1965, on a farm for farming purposes, shall cover only gasoline used during the taxable year on a farm for farming purposes. Therefore, gasoline on hand at the end of a taxable year as, for example, in fuel supply

(a) In general. Within 90 days after the date on which a notice of a final partnership adjustment (FPA) under section 6231(a)(3) with respect to any partnership taxable year is mailed, a partnership may file a petition for a readjustment of any partnership adjustment (as defined in §301.6241-1(a)(6)) reflected in the FPA for

accordance with this section to the transfer of estates of decedents who were residents of such foreign country, the President shall proclaim that the tax on the transfer of the estate of every decedent who was a resident of such foreign country at the time of his death shall, in the case of decedents dying after the date of such proclamation, be determined under this subchapter without regard to amendments made to

(a) In generalIf a domestic corporation transfers substantially all of the assets of a foreign branch (within the meaning of section 367(a)(3)(C), as in effect before the date of the enactment of the Tax Cuts and Jobs Act) to a specified 10-percent owned foreign corporation (as defined in

(a) General ruleIf the individual who is in physical possession of cash in excess of $10,000 does not claim such cash— (1) as his, or (2) as belonging to another person whose identity the Secretary can readily ascertain and who acknowledges ownership of such cash, then, for purposes of

), constitute a consent dividend for purposes of section 561 (relating to the deduction for dividends paid). (b) LimitationsA consent dividend shall not include— (1) an amount specified in a consent which, if distributed in money, would constitute, or be part of, a distribution which would be disqualified for purposes of the

retiree benefit plansAs of February 1, 1993, the settlors of the 1950 UMWA Benefit Plan and the 1974 UMWA Benefit Plan shall cause such plans to be merged into the Combined Fund, and such merger shall not be treated as an employer withdrawal for purposes of any 1988 coal wage agreement. (3) Treatment of planThe Combined Fund shall be— (A) a plan described in

subparagraph, stock owned by a corporation means stock owned directly plus stock owned with the application of the constructive ownership rules of paragraph (b) (1) and (4) of §1.1563-3, relating to options and attribution from corporations. In determining whether the stock owned by a corporation possesses the requisite percentage of the total combined voting power of all classes of stock entitled to vote

This section lists the captions that appear in the regulations under section 461 of the Internal Revenue Code. §1.461-1   General rule for taxable year of deduction. (a) General rule. (1) Taxpayer using cash receipts and disbursements method

This section lists the headings for §§1.909-1 through 1.909-6. §1.909-1   Definitions and special rules. (a) Definitions. (b) Taxes paid or

This section lists captions contained in §§1.1361-1, 1.1361-2, 1.1361-3, 1.1361-4, 1.1361-5, and 1.1361-6. §1.1361-1 S Corporation defined. (a) In

taxable year a written statement containing the information described in paragraph (a)(3) of this section. This section shall not apply to a real estate mortgage investment conduit (REMIC) treated as a partnership under subtitle F of the Code by reason of section 860F(e). For the reporting requirements applicable to REMICs see §1.6031(b)-2T. (2)

(a) Scope of section 2702. Section 2702 provides special rules to determine the amount of the gift when an individual makes a transfer in trust to (or for the benefit of) a member of the individual's family and the individual or an applicable family member retains an interest in the trust. Section 25.2702-4 treats certain

use of the recapped or retreaded tire, is immaterial. The controlling factor is whether the tire resulting from the recapping or retreading is of a type that is used otherwise than on a highway vehicle. For definition of “tires of the type used on highway vehicles”, see paragraph (c) of §48.4072-1. (b) Sales for resale for nontaxable

(a) Amounts to be released—(1) Dividends derived from domestic corporation. If United States tax has been withheld at the statutory rate on or after January 1, 1957, from dividends described in §514.2(a) and derived from a domestic corporation by a nonresident alien (including a nonresident

(a) Treaty provisions (1) In generalThe provisions of this title shall be applied to any taxpayer with due regard to any treaty obligation of the United States which applies to such taxpayer. (2) Cross referenceFor relationship between treaties and this title, see