beneficiary is not permitted to elect the exact throwback method provided in section 669(a)(1)(A). See §1.669(a)-4 for the computation of the tax on an accumulation distribution by the short-cut throwback method provided in section 669(a)(1)(B) under these circumstances. (b) Computation of tax. The tax referred to in paragraph (a

country where it is a resident; and (4) The transaction to which the qualified fails charge relates is attributable to the qualified business unit. A transaction will be treated as attributable to a qualified business unit if it satisfies the principles of §1.864-4(c)(5)(iii) (substituting “qualified business unit” for “U.S. office”). (c

(a) Reasonable cause for failure to comply—(1) Request for relief. If an 80-percent distributee, a distributee that is a section 1248 shareholder, or the domestic distributing corporation (reporting person) fails to timely comply with any requirement under §1.1248(f)-2, the failure

This section contains a listing of the paragraph headings for §§1.1298-1 and 1.1298-3. §1.1298-1   Section 1298(f) annual reporting requirements for United

This section lists the major captions that appear in §§1.6050I-1 and 1.6050I-2. §1.6050I-1   Returns relating to cash in excess of $10,000 received in a

, shall be drawn by the taxpayer to its own order and forwarded to the Administration in Washington, DC, with appropriate explanation of the purpose of the proposed withdrawal. Such withdrawals may occur by reason of a determination by the Administration that the taxpayer is not entitled to the benefits of section 511 of the Act (see §2.1-5), or that a particular deposit has been improperly made (see

(a) General rule. No suit or proceeding, except as otherwise provided in section 6532(c)(2) and paragraph (b) of this section, under section 7426 and §301.7426-1 relating to civil actions by persons other than taxpayers, shall be begun after the expiration of 9 months from the date of levy or agreement under section 6325(b)(3

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

such tanks are housed; and (3) Any doors from which access may be gained from the outside to rooms or buildings containing spirits stored in portable bulk containers. (f) Specifications for locks. Locks meeting the specifications in this section or other locks that have been approved for use by the appropriate TTB officer are approved locks for the purpose of

(a) The amount of excise taxes collected on rum that is imported into the United States from areas other than Puerto Rico and the Virgin Islands shall be deposited into the Treasuries of Puerto Rico and the Virgin Islands at the rate prescribed in 26 U.S.C. 7652(f). The distribution of such amount between Puerto Rico and the Virgin Islands shall be computed by using

compensation law or UC law means the law of a State approved under Section 3304(a) of the Internal Revenue Code of 1986 (26 U.S.C. 3304(a)). State Workforce Agency or SWA means the agency of the State charged with the administration of the State's

desired or necessary, the Department may obtain information from the IRS pursuant to 26 U.S.C. 6103(m)(2)(4) or (5). (iii) Given the debtor at least 60 days to present evidence that all or part of the debt is not past-due or not legally enforceable, considered any evidence presented by the debtor, and determined that the debt is past-due and legally

(a) Maximum Deposits.—The amount deposited in a capital construction fund for a taxable year may not exceed the sum of— (1) that portion of the taxable income of the owner or lessee for the taxable year (computed under chapter 1 of the Internal Revenue Code of 1986 (26 U.S.C. ch. 1) but

Firearms means any weapon, silencer, or destructive device designed to, or readily convertible to, expel a projectile by the action of an explosive, as defined in the Internal Revenue Code (26 U.S.C. 5845). Excludes antique firearms as defined in

Pub. L. 91–172, title IX, §962(a), Dec. 30, 1969, 83 Stat. 736, provided that: "The amendments made by sections 951, 953, 954(c) and (e), 955, 956, 958, and 960(c), (d), (e), (g), and (j) [amending this section and

disclosure of return or return information under section 6103 if such request is made in accordance with the requirements of such section; or (3) by the Secretary of the Treasury as a consequence of the implementation of a change in tax policy. (d) PenaltyAny person who willfully violates subsection (a) or fails to report