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section 165 and the regulations thereunder. For the disallowance of deductions for worthless securities issued by a political party, see §1.271-1. (b) Nature of loss allowable. To be allowable as a deduction under section 165(a), a loss must be evidenced by closed and completed transactions, fixed by identifiable events, and, except
Other forfeiture rules—(i) Withdrawal of mandatory contributions. For rules allowing forfeitures on account of the withdrawal of mandatory contributions, see §1.411(a)-7(d) (2) and (3). (ii) Additional requirements. For additional requirements relating to
(a) Definitions. The definitions in this section apply only for purposes of this section and §§54.4980H-2 through 54.4980H-6. (1) Administrative period. The term administrative period means an optional period
health or substance use disorder benefits, the entity shall ensure that the financial requirements and treatment limitations applicable to such mental health or substance use disorder benefits comply with the requirements of section 300gg–26(a) of this title in the same manner as such requirements apply to a group health plan. In applying the previous sentence with respect to requirements under
Regulatory effective dates—(1) In general. Except as otherwise provided in this section, §§1.410(b)-2 through 1.410(b)-9 apply to plan years beginning on or after January 1, 1994. (2) Plans of tax-exempt organizations. In the case of plans maintained by organizations exempt from
interest on obligations of the United States which, by reason of section 882 (d) or (e) and §1.882-2, is treated as effectively connected for the taxable year with the conduct of a trade or business in the United States by that corporation. A foreign corporation to which this section applies must segregate its gross income for the taxable year into two categories, namely, the income which is effectively
allowable under §1.199-1(a) (section 199 deduction) is determined at the partner level. As a result, each partner must compute its deduction separately. The section 199 deduction has no effect on the adjusted basis of the partner's interest in the partnership. Except as provided by publication pursuant to paragraph (b)(1)(ii) of this section, for purposes of this section, each partner is allocated, in
(a) In generalFor purposes of section 38, the amount of the low-income housing credit determined under this section for any taxable year in the credit period shall be an amount equal to— (1) the applicable percentage of (2) the qualified basis of each qualified low
general. An RPE must determine and report information attributable to any trades or businesses it is engaged in necessary for its owners to determine their section 199A deduction. (2) Computational rules. Using the following four rules, an RPE must determine the items necessary for individuals who own interests in the RPE to calculate their section 199A deduction under
§48.4101-1(a). For the rule providing that no deposit is required in the case of the tax imposed under this paragraph (b)(1)(iii), see §40.6302(c)-1(f)(4) of this chapter. For the rule allowing inspections of facilities where gasohol is produced, see section 4083.
§§1.460-2 and 1.460-3, respectively. A taxpayer generally must determine the income from a long-term contract using the percentage-of-completion method described in §1.460-4(b) (PCM) and the cost allocation rules described in §1.460
(a) Included property—(1) In general. For purposes of section 956(a) and §1.956-1, United States property is (except as provided in paragraph (b) of this section) any property acquired (within the meaning of paragraph (d)(1) of this section) by a foreign corporation (whether or not a
Claim for deduction. A claim for deduction under this section shall be made by the acquiring corporation on Form 976 and shall be filed within 120 days after the date of the determination. The form shall contain, or be accompanied by, the information required under §1.860-2(b)(2) in sufficient detail to properly identify the facts with respect to the distributor or transferor corporation
connection with, the conduct of a commercial banking function or other commercial activity by such bank. For purposes of this section and paragraph (i) of §1.1441-4, obligations of the United States or of any agency or instrumentality thereof include beneficial interests, participations, and other instruments issued under section 302(c) of the Federal National Mortgage Association Charter Act (
moves to Puerto Rico, where he purchases a house and accepts a permanent position with a local employer. For the remainder of the year and for the following three taxable years, E continues to live and work in Puerto Rico and has a closer connection to Puerto Rico than to the United States or any foreign country. Assuming that E otherwise meets the requirements under section 937(a) and §1.937-1(b) and
extension will be allowed pursuant to §1.6081-1(b) beyond the automatic six-month extension provided by this section. In the case of a partnership described in §1.6081-5(a)(1), the automatic extension of time to file allowed under this section runs concurrently with an extension of time to file granted