Taxpayer using an accrual method—(i) In general. Under an accrual method of accounting, a liability (as defined in §1.446-1(c)(1)(ii)(B)) is incurred, and generally is taken into account for Federal income tax purposes, in the taxable year in which all the events have occurred that establish the fact of the liability, the amount of the liability can

§§1.861-8T through 1.861-12T and without regard to the rules of this section. The choice is made on an annual basis and, thus, is not binding with respect to subsequent tax years. (2) Transition relief. This section contains transitional rules that limit the application of the rules for allocating and apportioning interest expense of corporate

section. (2) For the definition of terms used in this section see section 1388 and §1.1388-1; to determine the payment period for a taxable year, see section 1382(d) and §1.1382-4. (b) Deduction for

), substitute a new statutory option (new option) for an outstanding statutory option (old option) or assume an old option without such substitution or assumption being considered a modification of the old option. For the definition of modification, see paragraph (e) of this section. (ii) For purposes of §§1.421-1 through 1.424-1, the

(a) All insurance companies, other than life or mutual or foreign insurance companies not carrying on an insurance business within the United States, and all mutual marine insurance companies and mutual fire insurance companies exclusively issuing either perpetual policies, or policies for which the sole premium charged is a single deposit which, except for such deduction of underwriting costs as may be provided, is refundable upon cancellation or expiration of the

or not the collecting agent had attempted collection or the person liable for the tax had refused payment thereof. For purposes of this section, the report due date is— (a) In the case of a person using the alternative method of making deposits described in §40.6302(c)-3 of this chapter, the due date of the return on which the item of adjustment relating to

, and paragraphs (c) through (f) of this section provide rules for determining this amount. Paragraph (g) provides definitions. Paragraph (h) of this section provides examples illustrating the application of the rules of this section. Paragraph (i) of this section provides dates of applicability. This section applies after taking into account §1.7874-2(e). See

§1.826-1. (b) Information required of consenting attorney-in-fact. Every attorney-in-fact making the consent provided by section 826(c)(2) and paragraph (a) of this section shall, in the manner prescribed by paragraph (c) of this section, furnish the following information for each taxable year during which the consent provided by section 826(c)(2) and

1This excess is subject to determination of price under section 472(b)(1) and §1.472-2. The 20 units of raw material in the raw state plus 15 units of raw material in goods in process make up the 35 units of raw material that were contained in the opening inventory. (d) For the

§ 10.3. (6) A tax return includes an amended tax return and a claim for refund. (7) Service means the Internal Revenue Service. (8) Tax return preparer means any individual within the meaning of section 7701(a)(36) and

“returned credit component” for purposes of determining the State housing credit ceiling under section 42(h)(3)(C) for the calendar year following the calendar year of the allocation. See §1.42-14(d)(1). (b) Carryover-allocation basis—(1) In general. Subject to the limitations of paragraph (b)(2

) Data basis for definitions; reflection of technical changes or modificationsWhere appropriate, the definitions in subsection (a) shall be based, with respect to any fiscal year, on the most recent data compiled by the United States Bureau of the Census and the latest published reports of the Office of Management and Budget available ninety days prior to the beginning of such fiscal year. The Office may by regulation change or otherwise modify the meaning of the terms defined in

which gain was not recognized under section 1034, the provisions of §1.1038-1 (other than paragraph (a) thereof) shall not, and this section shall, apply to the reacquisition of such property if the property is resold by the seller within one year after the date of the reacquisition. For purposes of this section an election under section 121 shall be considered to be in effect with respect to the

§1.482-1(c) (Best method rule). Example 7. Preference for comparable uncontrolled transaction method. (i) USpharm, a U.S. pharmaceutical company, develops a new drug Z that is a safe and effective treatment for the disease zeezee. USpharm has obtained patents covering drug Z in the

(a) If contributions are paid by an employer under an annuity plan for employees and the general conditions and limitations applicable to deductions for such contributions are satisfied (see §1.404(a)-1), the contributions are deductible under section 404(a)(2) if the further conditions provided therein are satisfied. For the meaning of “annuity plan” as used

§ 26.08 Exemption procedures. (a) The Commandant has redelegated to the Assistant Commandant for Prevention Policy, U.S. Coast Guard Headquarters, with the reservation that this authority shall not be further redelegated, the authority to grant exemptions from provisions of the Vessel Bridge-to-Bridge Radiotelephone Act and this

). However, both section 101(c) and section 101(d) may apply to payments received under a single life insurance contract. For provisions relating to the application of this rule to payments received under a permanent life insurance policy with a family income rider attached, see paragraph (h) of §1.101-4. (b) Determination of “present value

Time and manner of making election. The election shall be made on or before December 11, 1961, by filing a statement with the district director with whom the taxpayer's income tax return for the taxable year in which the election is made is required to be filed. The statement shall include the following: (1) A clear indication that an election is being made under the Act, and (2) The taxable years to which the election

Time and manner of making election. The election shall be made on or before February 14, 1962, by filing a statement with the district director with whom the taxpayer's income tax return for the taxable year in which the election is made is required to be filed. The statement shall include the following: (1) A clear indication that an election is being made under section 2 of the Act, and (2) The taxable years to which

corporation stock and purports to aid the S corporation and its shareholders in avoiding taxable income. The tax-exempt entity facilitates Transaction A by reason of its tax-exempt, tax indifferent or tax-favored status. Accordingly, the tax-exempt entity is a party to Transaction A for purposes of sections 4965 and 6033(a)(2). See §601.601(d)(2)(ii)(

The appropriate TTB officers are authorized and required to make all inquiries necessary to the determination and assessment of all taxes imposed under the provisions of 26 U.S.C. enforced and administered by the Bureau. The appropriate TTB officers are further authorized and required to make the determinations and the assessments of such taxes. The term “taxes” includes interest, additional amounts, additions to the taxes, and assessable penalties. The authority of

FR 32767, July 28, 1978] {"origins":[{"level":"part","identifier":"101-26","label_level":"Part 101-26","hierarchy":{"title":"41","subtitle":"C","chapter":"101","subchapter":"E","part":"101-26"},"current":false,"authority":["\u003ca href=\"https://www.govinfo.gov/link/uscode/40/121\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e40 U.S.C. 121(c)\u003c/a\u003e.\n"],"source":[],"link":"/current

in §1.1502-75(d)(2)(ii) and subparagraph (3) of this paragraph), (ii) A separate return year of any corporation which was a member of the group for each day of such year, or (iii) A separate return year of a predecessor of any member if such predecessor was a member of the group for each day of such year,

expenditures with respect to such property, and (iv) enables the installation and use of any property described in subclause (I) or (II) of clause (iii). (3) Eligible fuelFor purposes of paragraph (2), the term "eligible fuel" means— (A) biodiesel and renewable diesel (within the meaning of

deferred under section 455 or Rev. Proc. 2004-34 (2004-1 CB 991 (June 1, 2004)) (or any successor revenue procedure) (see §601.601(d)(2)(ii)(b)). (b) Effective/applicability dates. This section applies to loss corporations that have undergone an ownership change on or after June 11, 2010. For loss corporations that have undergone an

(a) For the purpose of computing time limits under the Treaty, the priority date shall be defined as in PCT Art. 2(xi). (b) When a claimed priority date is corrected under PCT Rule 26bis.1(a), or a priority claim is added under PCT Rule 26bis.1(a), withdrawn under PCT Rule 90bis.3, or considered not to have been made

(a) Grounds for disapproval. The appropriate TTB officer may disapprove any bond or consent of surety required by this part if the principal or any person having ownership, control or responsibility for actively managing the business of the surety has been previously convicted, in a court of competent jurisdiction of: (1) Any fraudulent noncompliance with any provision of any law of the United

For each product to be tax determined using a standard effective tax rate in accordance with §19.248, a proprietor must prepare a record of the standard effective tax rate computation showing, for one proof gallon of the finished product, the following information: (a) The name of the product; (b) The