gain recognized by the partner under section 731(a) on the distribution of money in the same distribution or any related distribution. See §1.704-4(e)(1) for a determination of the distributee partner's adjusted tax basis in a distribution subject to section 704(c)(1)(B). (b) Distributee partner's adjusted tax basis in distributed

operations for the taxable year by reason of section 809(a)(1)), the amount of such excess shall be taken into account as a net decrease referred to in section 809(c)(2) and paragraph (a)(2) of §1.809-4 in determining gain or loss from operations. (2) Adjustment for increase. Section 810(b) provides that if the sum of the items

For purposes of this part— (1) Group health planThe term "group health plan" means an employee welfare benefit plan providing medical care (as defined in section 213(d) of title 26) to participants or beneficiaries directly or through insurance, reimbursement, or otherwise. Such term shall not include any

the 1990 1-hour ozone NAAQS, triggering the requirement for the State to establish an enhanced I/M program for this area.[1] In 1996, Georgia submitted its enhanced I/M program to EPA for incorporation into the SIP. EPA granted interim approval of the State's program. See 62 FR 42916 (August 11, 1997). Full approval was subsequently granted. See 65 FR 4133 (January 26, 2000). Since that time, EPA has approved several SIP revisions regarding the State's I/M

(a) In general. For purposes of §1.414(c)-2 (b)(2)(i) and (c)(2), the term “interest” and the term “stock” do not include an interest which is treated as not outstanding under paragraph (b) of this section in the case of a parent-subsidiary group of trades or businesses under common control or under paragraph (c) of this

thereunder. For example, a taxpayer that is required to use a calendar year under §1.441-1(b)(2)(i)(D) is not an eligible taxpayer. (4) Example. The provisions of this paragraph (a) are illustrated by the following example:

furnished or rendered to the tenants of the real estate investment trust or, primarily for the convenience or benefit of the tenant, to the guests, customers, or subtenants of the tenant. The service must be furnished through an independent contractor from whom the trust does not derive or receive any income. See paragraph (b)(5) of this section. For taxable years beginning before October 5, 1976, the rules in paragraph (b)(3) of 26 CFR 1.856-4 (revised as of April 1, 1977), relating to the furnishing

Pub. L. 97–248, title II, §282(a), Sept. 3, 1982, 96 Stat. 568; Pub. L. 98–369, div. A, title I, §26, July 18, 1984, 98 Stat. 507;

required by this subparagraph. See paragraph (f) of this section for an exception for employers filing composite returns from the requirement that statements for employees be on Form W-2. For the requirements relating to Form W-2 with respect to qualified State individual income taxes, see paragraphs (d)(3)(ii) of §301.6361-1 of this chapter (regulations on Procedure and Administration). Each

(a) Business entities. For purposes of this section and §301.7701-3, a business entity is any entity recognized for federal tax purposes (including an entity with a single owner that may be disregarded as an entity separate from its owner under

(a) In general. Notices and elections under the following sections must be filed with the Internal Revenue Service, 1111 Constitution Avenue, NW, Attention: T:GE:TEB:O, Washington, DC 20224 or such other place designated by publication of a notice in the Internal Revenue Bulletin— (1) Section 1.141

within the meaning of §1.414(c)-2 for any period shall be treated as employed by a single employer. See sections 401, 408(k), 410, 411, 415, and 416 and the regulations thereunder for rules relating to employees of trades or businesses which are under common control. See §1.414(c)-5 for

power is limited by a reasonably definite external standard set forth in the trust instrument (see paragraph (b)(5) of §1.674(b)-1 with respect to what constitutes a reasonably definite standard). See, however, the limitations set forth in §1.674(d)-2.

Section 1.831-1 is applicable only to taxable years beginning after December 31, 1953, but before January 1, 1963, and ending after August 16, 1954, and all references therein to sections of the Code and regulations are to sections of the Internal Revenue Code of 1954 and the regulations thereunder before amendments.

This section lists the headings for §1.904(i)-1. §1.904(i)-1   Limitation on use of deconsolidation to avoid foreign tax credit limitations.

(a) In general. Except as provided in §1.1362-5, a small business corporation as defined in section 1361 may elect to be an S corporation under section 1362(a). An election may be made only with the consent of all of the shareholders of the corporation at the time of the election. See

The regulations in §§1.1402(e)-2A through 1.1402(e)-4A relate to section 1402(e) as amended by section 115(b)(2) of the Social Security Amendments of 1967 (81 Stat. 839) and apply to taxable years ending after 1967. Section 1.1402(e)-5A reflects

In accordance with section 269B(a)(1), a stapled foreign corporation is subject to the same taxes that apply to a domestic corporation under title 26 of the Internal Revenue Code. For provisions concerning taxes other than income for which the stapled foreign corporation is liable, apply the same rules as set forth in §1.269B-1(a) through (f)(1)(i), and (g) of this

liability incurred at any factory covered by the bond. (72 Stat. 1421; 26 U.S.C. 5711) [26 FR 8174, Aug. 31, 1961. Redesignated at 40 FR 16835, Apr. 15, 1975; 54 FR 48839, Nov. 27, 1989, and further redesignated by T.D. ATF-460, 66 FR 39093, July 27, 2001, as amended by T.D. TTB-91, 76 FR 5480, Feb. 1, 2011]

small cigars, the classification of the product for tax purposes (i.e., either “small” or “little”). (Sec. 202, Pub. L. 85-859, 72 Stat. 1422 (26 U.S.C. 5723)) [T.D. ATF-80, 46 FR 18310, Mar. 24, 1981. Redesignated and amended by T.D. TTB-16, 69 FR 52424, 52425, Aug. 26, 2004]

If a taxpayer changes his annual accounting period, the new accounting period shall become the taxpayer's taxable year only if the change is approved by the Secretary. For purposes of this subtitle, if a taxpayer to whom section 441(g) applies adopts an annual accounting period (as defined in

This subpart covers the establishment and operation of alcohol fuel plants. (26 U.S.C. 5181)

employee's gross income on account of the availability of the vehicle is $500 ($2,000−$1,500). For purposes of this section, the term “vehicle” has the meaning given the term in §1.61-21(e)(2). Generally, when determining the amount of an employee's working condition fringe, miles accumulated on the vehicle by all employees of the employer during the period in which the vehicle is available to the employee

A proprietor must maintain records of the receipt, use, and disposition of liquor bottles. (26 U.S.C. 5207)

corporation (as defined in section 1371(b)), or a beneficiary of an estate or trust, see §§1.48-5 and 1.48-6, respectively, for apportionment of the basis (or cost) of section 38 property placed in service by such corporation, estate, or trust. For the definitions of new section 38 property and used section 38 property, see

§1.901(m)-6 for rules regarding the continued application of section 901(m) if the RFA has any unallocated basis difference after determining the disposition amount under paragraph (c)(2)(ii)(A) or (B) of this section, as applicable. (A) Positive basis difference. If the disposition of an RFA is not fully taxable for

gross income (as defined in section 67(e) and as adjusted under §1.1411-10(e)(2), if applicable) for such taxable year; over (2) The dollar amount at which the highest tax bracket in section 1(e) begins for such taxable year. (2) Taxable year of

taken into account for purposes of sections 902 or 960, or for purposes of determining earnings and profits under section 964(a), before the taxable year in which the related income is taken into account by the payor section 902 corporation, a section 902 shareholder of the section 902 corporation, or a member of the section 902 shareholder's consolidated group. See §1.909-3(a) for rules relating to

(a) Information reporting requirement—(1) Overview. The information reporting requirements of section 6050H, this section, and §1.6050H-2 apply to an interest recipient who receives at least $600 of interest on a qualified mortgage for a calendar year or who makes a reimbursement of