section 1274(d) without regard to paragraph (2) thereof) as of the beginning of the taxpayer's holding period, over (2) the amount actually includible in gross income with respect to such interest by the taxpayer. (d) Cross referenceFor special rules in determining inclusion of original issue discount on regular interests, see

For purposes of sections 582 and 584, the term "bank" means a bank or trust company incorporated and doing business under the laws of the United States (including laws relating to the District of Columbia) or of any State, a substantial part of the business of which consists of receiving deposits and making loans and discounts, or of exercising fiduciary

Prior Provisions A prior section 5843, act Aug. 16, 1954, ch. 736, 68A Stat. 725, as amended by act Sept. 2, 1958,

Prior Provisions A prior section 5849, Pub. L. 85–859, title II, §203(g)(1), Sept. 2, 1958, 72 Stat. 1427, consisted of provisions similar to those comprising this section, prior to the

such date. In the case of construction, reconstruction, or erection of such property commenced before January 1, 1962, and completed after December 31, 1961, there shall be taken into account as the basis of new section 38 property in determining qualified investment only that portion of the basis which is properly attributable to contruction, reconstruction, or erection after December 31, 1961. See

corporation is increased thereby. Such distribution will be deemed to be a distribution of the stock of such corporation made by the corporation to such shareholder with respect to his stock. Depending upon the facts presented, the distribution may be deemed to be made in common or preferred stock. For example, where a redemption premium exists with respect to a class of preferred stock under the circumstances described in

(a) Introduction. Section 468A provides an elective method for taking into account nuclear decommissioning costs for Federal income tax purposes. In general, an eligible taxpayer that elects the application of section 468A pursuant to the rules contained in §1.468A-7 is allowed a deduction (as determined under

(a) General rule. Amounts specified in consents filed by shareholders or other beneficial owners of a corporation described in §1.565-1(a) are not treated as consent dividends to the extent that— (1) They would constitute a preferential dividend or (2) They would

This section lists the provisions under section 902. §1.902-1   Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation. (a) Definitions and special effective date. (1

(a) Repeal of section 963. Except as provided in paragraphs (b) and (c) of this section, the provisions of section 963 and §§1.963-1 through 1.963-7 are repealed for taxable years of foreign corporations beginning after December 31, 1975, and for taxable years of United States shareholders (within the meaning of section 951(b

, this paragraph (b) applies to any debt instrument that is not publicly offered (within the meaning of §1.1275-1(h)), is issued in physical form, and has OID. The issuer of any such debt instrument must legend the instrument by stating on the face of the instrument that the debt instrument was issued with OID. In addition, the issuer must either— (i) Set forth on the

(a) In general. Whether services performed after 1954 constitute employment is determined in accordance with the provisions of section 3121(b). (b) Services performed within the United States. Services performed after 1954 within the United States (see

withheld erroneously under section 3406 only if the amount is withheld because of an error by the payor or broker (e.g., an error in flagging or identifying an account that is subject to withholding under section 3406). The payor or broker may, in its discretion, treat the amount withheld as an amount erroneously withheld and refund it to the payee if— (i) The payor or broker requires a payee described in

Notes and Related Subsidiaries Effective Date of 1988 Amendment Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a)

(a) Valuation rules (1) In generalSolely for purposes of determining whether a transfer of an interest in trust to (or for the benefit of) a member of the transferor's family is a gift (and the value of such transfer), the value of any interest in such trust retained by the transferor or any applicable family member (as defined in

foreign person, each issuer of a life insurance contract shall make a return (at such time and in such manner as the Secretary shall prescribe) setting forth— (A) the name, address, and TIN of the seller who transfers any interest in such contract in such sale, (B) the investment in the contract (as defined in section 72(e)(6)) with

Coordinator). (6) Summaries of Board decisions and United States positionsFollowing each meeting of the Board of the Global Fund, the Coordinator of United States Government Activities to Combat HIV/AIDS Globally shall report on the public website of the Coordinator a summary of Board decisions and how the United States Government voted and its positions on such decisions. (e) Interagency technical review panel

Regardless of which authority is being relied upon for reimbursement of the cost of ambulance transportation, the rates paid are determined by existing regulations. In many instances VA pays the actual cost of the transportation, and in other circumstances, when payment is accepted by vendors, regulations state that it will serve as payment in full. VA therefore makes no changes to the regulations based on this comment. The same commenter

Regardless of which authority is being relied upon for reimbursement of the cost of ambulance transportation, the rates paid are determined by existing regulations. In many instances VA pays the actual cost of the transportation, and in other circumstances, when payment is accepted by vendors, regulations state that it will serve as payment in full. VA therefore makes no changes to the regulations based on this comment. The same commenter

ADDRESSES: Comments and replies may be filed with the Board either via e-filing or in writing addressed to: Surface Transportation Board, Attn: Docket No. EP 760, 395 E Street SW, Washington, DC 20423-0001. Comments and replies will be posted to the Board's website at www.stb.gov. FOR FURTHER INFORMATION CONTACT: Amy

Testing group. All plans included in the testing group under §1.410(b)-7(e)(1), and only those plans, are taken into account in determining an employee's employee benefit percentage. (ii) Testing period. An employee's employee benefit percentage is determined on the basis of plan years ending with or

company shipping operations is an amount equal to the decrease for such year in such corporation's qualified investments in foreign base company shipping operations. Such decrease is, except as provided in §1.955A-4— (i) An amount equal to the excess of the amount of its qualified investments in foreign base company shipping operations at the close of the preceding

(a) Overview. This section provides rules relating to the tax imposed on ozone-depleting chemicals (ODCs) under section 4681, including rules for identifying taxable ODCs and determining when the tax is imposed, and rules prescribing special treatment for certain ODCs. See §52.4681-1(a)(1) and (c) for general rules and

section 401(c)(1) of title 26; or (B) which consists of one or more individual retirement accounts described in section 408 of title 26; to the extent that such plan's assets are held in one or more custodial accounts which qualify under

section 935 possession of which such individual is a citizen; and (C) With respect to an individual described in paragraph (a)(2)(iii) of this section, the section 935 possession from which such individual derives income. (iii) The rules of §1.937-1 will apply for determining whether an individual is a bona fide resident of a

(A) That portion of the stock received by the private foundation in the exchange which represents such excess is to be treated as an increase in the holdings of the private foundation in accordance with §53.4943-6 (d), and (B) Only the remaining portion of the stock received by the private foundation in the exchange shall be treated as

opportunity to make (or change) a cash or deferred election (as defined at §1.401(k)-1(a)(3)) between cash or a contribution to the plan. Further, an effective opportunity includes the right to have section 403(b) elective deferrals made on his or her behalf up to the lesser of the applicable limits in

submit information that you consider to be CBI or otherwise protected through http://www.regulations.gov or email. The http://www.regulations.gov website is an “anonymous access” system, which means the EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an email comment directly to the EPA without going through http://www.regulations.gov, your email address will be automatically captured and included as part

You may submit comments, identified by Docket No. R-1714 and RIN 7100 AF 88, by any of the following methods: Agency Website: http://www.federalreserve.gov. Follow the instructions for submitting comments at https://www.federalreserve.gov/​generalinfo/​foia/​ProposedRegs.cfm. Email: regs.comments@federalreserve.gov. Include docket