For regulations concerning interest on underpayments, etc., see §301.6601-1 of this chapter (Regulations on Procedure and Administration).

For regulations concerning the lien for taxes, see §301.6321-1 of this chapter (Regulations on Procedure and Administration).

See §31.3231(b)-1 for regulations relating to the term “in the service of an employer.”

For regulations under section 6411, see §§1.6411-1 to 1.6411-4, inclusive, of this chapter (Income Tax Regulations).

For regulations under section 6851, see §§1.6851-1 to 1.6851-3, inclusive, of this chapter (Income Tax Regulations).

the corporate level as if section 57 generally applied to the corporation. However, the items of tax preference so computed are treated as items of tax preference of the shareholders of such corporation and not as items of tax preference of such corporation (except as provided in paragraph (c) of this section). The items of tax preference specified in section 57(a)(1) and §1.57-1(a) (excess

nuclear decommissioning fund must be computed on the basis of the taxable year of the electing taxpayer. If an electing taxpayer changes its taxable year, each nuclear decommissioning fund of the electing taxpayer must change to the new taxable year. See section 442 and §1.442-1 for rules relating to the change to a new taxable year.

§1.522-2. For the purpose of any law which refers to organizations exempt from income taxes such an association shall, however, be considered as an organization exempt under section 501. Thus, the provisions of section 243, providing a credit for dividends received from a domestic corporation subject to taxation, are not applicable to dividends received from a cooperative association subject to section

taxable year with respect to which the liability for personal holding company tax exists, if it had been distributed during such year. See section 562 and §§1.562-1 through 1.562-3. In this connection, it should be noted that under section 316(b)(2), the term dividend means (in addition to the usual meaning under section 316(a)) any distribution of property

(a) In general. The character of exchange gain or loss recognized on a section 988 transaction is governed by section 988 and this section. Except as otherwise provided in section 988(c)(1)(E), section 1092, §1.988-5 and this section, exchange gain or loss realized with respect to a section 988 transaction (including a section

paragraph (b) (1), (3), (4), or (5) of this section. For purposes of this section, distributions by the lower tier subsidiary will be considered attributable to active earnings and profits according to the rule in paragraph (c) of this section. This paragraph (b)(2) does not apply to any member of a consolidated group (as defined in §1.1502-1(h)). (3)

(2) For purposes of subparagraph (1)(ii)(a) of this paragraph, a legally adopted son or daughter of an individual, a child (described in paragraph (c)(2) of §1.152-2) who is a member of an individual's household if placed with such individual by an authorized placement agency (as defined in paragraph (c)(2) of

of the Internal Revenue Code. (b) Actual, direct economic damages—(1) Definition. See §301.7433-1(b)(1). (2) Litigation costs and administrative costs not recoverable as actual, direct economic damages. Litigation

Qualified nonprofit organization. Defined by the CFP authorizing statute (Pub. L. 110-234; 122 Stat. at 1281), an organization that is described in Section 170(h)(3) of the Internal Revenue Code of 1986 (26 U.S.C. 170(h)(3)) and operates in accordance with one or more of the conservation purposes specified in Section 170(h)(4)(A) of that Code (

(a) Judicial proceedingsIf the United States is not joined as a party, a judgment in any civil action or suit described in subsection (a) of section 2410 of title 28 of the United States Code, or a judicial sale pursuant to such a judgment, with respect to property on which the United States has or claims a lien under the provisions

For the rules applicable under section 4264(d) see §49.4261-4 relating to payments made within the United States.

expected to be made). Moreover, once a principal payment reduces a no-inclusion with respect to a specified payment, it is not again taken into account for purposes of applying this paragraph (a)(4) to another specified payment. See §1.267A-6(c)(1)(vi) for an example illustrating the application of this paragraph (a)(4). (5) Deemed

Exception to general rule. (1) The registered management investment company, which for the taxable year meets the requirements of paragraph (a) of this section, may (subject to the limitations of section 851(e)(2) and paragraph (c) of this section) in the computation of 50 percent of the value of its assets under section 851(b)(4)(A) and paragraph (c)(1) of §1.851-2

(a) Furnishing identifying number. (1) Each filed return of tax or claim for refund of tax under the Internal Revenue Code prepared by one or more tax return preparers must include the identifying number of the tax return preparer required by §1.6695-1(b) to sign the return or claim for refund

(a) In general. Even though a notice of a lien imposed by section 6321 is filed in accordance with §301.6323(f)-1, the lien is not valid with respect to a security interest which: (1) Comes into existence after the tax lien filing, (2) Is in qualified

(d) No administrative summons when there is Justice Department referral (1) Limitation of authorityNo summons may be issued under this title, and the Secretary may not begin any action under section 7604 to enforce any summons, with respect to any person if a Justice Department referral is in effect with respect to

(a) In general. Bonds of an issue are private activity bonds if more than the lesser of 5 percent or $5 million of the proceeds of the issue is to be used (directly or indirectly) to make or finance loans to persons other than governmental persons. Section 1.141-2(d) applies in determining whether the private loan financing test

classification election made under §301.7701-3 of this chapter that is filed on or after July 29, 2014, and that is effective on or before July 21, 2014, the transactions set forth under section 901(m)(2) are CAAs and the assets that are relevant foreign assets with respect to the CAA under section 901(m)(4) are RFAs. (e) Examples. The

§1.1298-1(b)(3)(i) (imposing an information reporting requirement on domestic liquidating trusts and fixed investment trusts). (8) Indirect shareholder—(i) In general. An indirect shareholder of a PFIC is a United States person that indirectly owns stock of a PFIC. A

(a) Imposition of tax—(1) Initial tax. Except as provided in paragraph (b) of this section, section 4942(a) imposes an excise tax of 15 percent on the undistributed income (as defined in paragraph (a) of §53.4942(a)-2) of a private foundation for any taxable year which has not been

Individuals covered. Paragraph (b) of this section applies only to an individual who, for a taxable year, is described in paragraph (a)(2) of §1.935-1 of this chapter (Income Tax Regulations) and has (or in the case of a joint return, such individual and his spouse have)— (i) Adjusted gross income of $50,000 or more, and

For provisions relating to the requirement of returns by exempt organizations, see §1.6033-1 of this chapter (Income Tax Regulations).

For provisions relating to the signing of corporation income tax returns, see §1.6062-1 of this chapter (Income Tax Regulations).

For provisions relating to the signing of returns of partnership income, see §1.6063-1 of this chapter (Income Tax Regulations).

For regulations under section 6205, see §31.6205-1 of this chapter (Employment Tax Regulations). Deficiency Procedures