or corporation at no time during the taxable year in which such dividends are so received has no permanent establishment within the United States. Article I(a) of the convention, signed June 22, 1956. As to what constitutes a “permanent establishment” see Protocol III(a), in §514.1. (2) Thus, if a nonresident alien individual who is a resident of France performs

(a) Representations. (1) (i) If the offeror selects “does not” in paragraphs (c)(1) and/or (c)(2) of the provision at 52.204-26 or in paragraphs (v)(2)(i) and/or (v)(2)(ii) of the provision at

In any case where an individual is a member of a religious order (as defined in section 3121(r)(2) and paragraph (b) of §31.3121(r)-1) performing service in the exercise of duties required by such order, and an election of coverage under section 3121(r) and

to the time a contribution to a plan is deemed made for purposes of the minimum funding standard under section 412 are independent from the rules contained in section 404(a) (6) relating to the time a contribution to a plan is deemed made for purposes of claiming a deduction for such contribution under section 404. (Sec. 412(c)(10), Internal Revenue Code of 1954 (88 Stat. 917;

proprietor must use the bonded premises of a distilled spirits plant exclusively for distilled spirits operations. The proprietor must store packaged spirits, cases of spirits, or portable containers of spirits in a room or building on bonded premises. TTB may approve another method of storage as an alternate method or procedure. However, the proprietor must apply for, and receive approval for another method of storage from the appropriate TTB officer in accordance with

wines have been lawfully disposed of, or until a new bond has been submitted by the principal covering the spirits or wine. (b) Withdrawal or unit bonds. The surety will be relieved from liability for withdrawals made after the date specified in the notice, or upon the effective date of a new bond if one is given. (

(a) Distilling material. Generally, a proprietor may not remove distilling material from bonded premises before it is distilled. However, a proprietor may remove mash, wort, wash, or other distilling material: (1) To plant premises, other than bonded premises, for use in any business authorized under

wines and sells beer or offers beer for sale only as provided in §31.61 through §31.63 or §31.65(a). (

(a) A person (including an estate or trust (see section 642(f) and §1.642(f)-1) and a partnership (see section 703 and §1.703-1)) is entitled, by election, to a deduction with respect to the amortization of the adjusted basis (for determining gain) of an emergency

paragraphs (b)(1) through (8) of this section may not be released if confidential for protection cases. (d) A request for additional information concerning an inmate by a representative of the news media is referred to the Public Information Officer, Central Office

other vehicles must be removed from the immediate market premises. One space is 16w × 17d feet, and all trucks must fit within that area. There is only room for 15 spaces. (d) Signage. Participants must clearly display the name of their farm/business and post prices for all items being sold. (e) Clean-up. Participants are responsible for cleaning all trash and

. For definition of “recapture determination” see paragraph (a)(1) of §1.47-1. (2) Disposition of shareholder's interest. (i) If— (a) The basis (or cost) of section 38 property is apportioned, under

§ 548.302 Average earnings for period other than a workweek. (a) Section 548.3(b) authorizes as an established basic rate: “A rate per hour which is obtained by averaging the earnings, exclusive of payments described

Consideration of demands shall be within the province of the attorney representing the United States, who may raise any valid objection to the production of material or provision of testimony in response to the demand. [73 FR 72207, Nov. 26, 2008]

custody of those articles is subject to part 275 of the regulations of the Internal Revenue Service (26 CFR part 275) and tax is payable to Customs; and (3) Deposit of duties. Estimated Customs duties, taxes, and other charges, as set forth in subpart G of part 141 of this chapter, shall be deposited upon presentation of the combined entry. The port director shall then issue a permit for release on Customs Form 7501, or its

For provisions relating to the applicability of Federal and State laws, see section 4422 and §44.4422-1.

Under the provisions of section 2524, the charitable deduction provided for in section 2522 and the marital deduction provided for in section 2523 are allowable only to the extent that the gifts, with respect to which those deductions are authorized, are included in the “total amount of gifts” made during the “calendar period” (as defined in §25.2502-1(c)(1

(a) Scope. This section provides rules for the application of section 59A and the regulations thereunder (the section 59A regulations) to consolidated groups and their members (as defined in §1.1502-1(h) and (b), respectively). Rules in the section 59A regulations apply to consolidated

set forth in paragraph (c) of this section. The rules for determining when substantial authority exists are set forth in §1.6662-4(d). The rules for determining when there is adequate disclosure are set forth in §1.6662-4 (e) and (f). This penalty does not apply to the extent that the reasonable cause and good faith exception to this penalty set forth in §1.6664-4 applies.

(b) For purposes of §§54.4980B-1 through 54.4980B-10, health care has the same meaning as medical care under section 213(d). Thus, health care generally includes the diagnosis, cure, mitigation, treatment, or prevention of disease, and any other undertaking for the purpose of affecting any

entering our offices. We expect that the regulations will result in a safer environment for our personnel and the public who visit our facilities, while ensuring that our personnel can continue to serve the American people with as little disruption to our operations as possible.