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(a) Ordinary income—(1) General rule.
(i) Except as otherwise provided in this section and §1.1252-2, if farm land is disposed of during a taxable year beginning after December 31, 1969, then under section 1252(a)(1) there shall be treated as gain from the
under the preceding sentence, the interest of the transferor's spouse (the successor holder) must be an interest that meets the requirements of a qualified annuity interest in accordance with §25.2702-3(b) and (d), or a qualified unitrust interest in accordance with §25.2702-3(c) and (d), but for
lobbying expenditures). This is generally accomplished by treating the members of an affiliated group as a single organization for purposes of measuring both lobbying expenditures and permitted lobbying expenditures. The anti-abuse rule is implemented by this §56.4911-7 and §§56.4911-8 and 56.4911-9. This §56.4911-7 defines the term “affiliated group of organizations” and defines the taxable year of an
(i) In generalAn action under subparagraph (A)(i) shall be governed under the rules and procedures set forth in section 42121(b) of title 49, United States Code.
(ii) ExceptionNotification made under
treatment on merger into RIC. (i) X, a calendar-year taxpayer, has qualified as a RIC since January 1, 1991. On May 31, 1994, Y, a C corporation and calendar-year taxpayer, transfers all of its property to X in a transaction that qualifies as a reorganization under section 368(a)(1)(C). X does not elect section 1374 treatment under paragraph (c) of this section and chooses not to rely on §1.337(d)-5
expressed in terms of FOGEI taxes but they apply to FORI taxes by substituting “FORI taxes” for “FOGEI taxes” whenever appropriate. For the treatment of withholding taxes, see paragraph (a)(8) of this section. FOGEI taxes are determined without any reduction under section 907(a). In addition, determination of FOGEI taxes will not be affected by recharacterization of FOGEI by section 907(c)(4). See
(a) In general. A corporation which meets the requirements described in §1.992-1 for treatment as a DISC for a taxable year, other than the 95 percent of gross receipts test described in §1.992-1(b) or the 95-percent assets test
or before January 4, 2001, if the distribution is made as part of a transaction described in, or substantially similar to, the transaction in Notice 99-59 (1999-2 C.B. 761), including transactions designed to reduce gain (see §601.601(d)(2) of this chapter). For rules for distributions on or before January 4, 2001 (other than distributions on or before that date to which this paragraph (g) applies
section 707(c) of a fixed amount.
(2) Liquidation, etc. rights
(A) In generalThe term "liquidation, put, call, or conversion right" means any liquidation, put, call, or conversion right, or any similar right, the exercise or nonexercise of which affects the value of the transferred interest.
in food plots may also be used by pocket gophers. We have revised the 4(d) rule provisions to except food plots under certain circumstances.
(6) Comment: One commenter stated that conversion of loblolly pine stands to longleaf pine stands is being done by willing landowners and that landowners may choose not to convert pine stands from loblolly to longleaf if they believe that silvicultural choices are not available, including the
may also be members of a consolidated group, and a controlled group loss may be subject to a consolidated section 382 limitation or subgroup section 382 limitation determined under §1.1502-93. Except as otherwise provided in this paragraph (f) and §§1.1502-91 through 1.1502-99,
(i) The rules of §1.937-1 will apply for determining whether an individual is a bona fide resident of the Virgin Islands;
(ii) The rules of §1.937-2 will apply for determining whether income is from sources within the Virgin Islands
(a) In general. For purposes of §§1.959-1 and 1.959-2, the source of the earnings and profits from which distributions are made by a foreign corporation as between earnings and profits attributable to increases in earnings invested in United States property, previously taxed subpart F income, previously excluded subpart F income
For regulations concerning the special lien for the estate tax, see §301.6324-1 of this chapter (Regulations on Procedure and Administration).
For regulations concerning the special lien for the gift tax, see §301.6324-1 of this chapter (Regulations on Procedure and Administration).
For provisions relating to requirement of estate tax returns, see §§20.6018-1 to 20.6018-4, inclusive, of this chapter (Estate Tax Regulations).
For provisions relating to requirement of return of electing small business corporation, see §1.6037-1 of this chapter (Income Tax Regulations).
For provisions relating to statements for employees regarding remuneration paid during calendar year, see §31.6051-1 of this chapter (Employment Tax Regulations).
For regulations under section 6413, see §§31.6413(a)-1 to 31.6413(c)-1, inclusive, of this chapter (Employment Tax Regulations).
For provisions relating to the obtaining of a license for the collection of foreign items, see section 7001 and §301.7001-1.
For provisions relating to the authority of internal revenue enforcement officers, see section 7608.
be made if another provision of the Internal Revenue Code or the regulations thereunder contemplates the event occurring before or after S's change in status. For example, S's items restored under §1.1502-13 immediately before it becomes a nonmember are taken into account in determining the basis of S's stock under
§1.704-1(b)(2)(iii)(c)), paragraph (d) Example 9 of this section (relating to the election under section 754 to adjust basis in partnership property), and paragraph (d) Examples 10 and 11 of this section (relating to the basis in property distributed by a partnership under section 732). See also, for
§56.4911-2 (without reference to §§56.4911-2(b)(3) and 56.4911-2(c)) and §56.4911-3. See, however, paragraph (d) of this section for exceptions to the general rule of this paragraph (a)(1).
section 6041 of the Internal Revenue Code. The plan must provide that the Medicaid agency complies with the information reporting requirements of section 6041 of the Internal Revenue Code (26 U.S.C. 6041). Section 6041 requires the filing of annual information returns showing amounts paid to providers, who are identified by name, address, and social security number or employer identification number
(a) In general. This section applies to distributions with respect to, or a disposition of, stock—
(1) To which, in connection with an exchange occurring before February 23, 2000, an amount has been attributed pursuant to §7.367(b)-9 or 7.367(b)-10 of this chapter (as in effect prior to February 23, 2000, see 26 CFR part 1 revised as of April 1, 1999); or
(2
) of this section, for purposes of section 403(b), an elective deferral only includes a contribution that is made pursuant to a cash or deferred election (as defined at §1.401(k)-1(a)(3)). Thus, for purposes of section 402(g)(3)(C), an elective deferral does not include a contribution that is made pursuant to an employee's one-time irrevocable election made on or before the employee's first
reasonable, is not sufficient to establish that the plan does not discriminate in favor of employees who are officers, shareholders, or highly compensated.
(Sec. 410, Internal Revenue Code of 1954 (88 Stat. 898; 26 U.S.C. 410))
[T.D. 7380, 40 FR 45816, Oct. 3, 1975, as amended by T.D. 7508, 42 FR 47197, Sept. 20
(a) As a recipient, you must use, except as provided in this subpart, the procedures and standards of part 26, §§26.61-91 for certification of ACDBEs to participate in your concessions program. Your ACDBE program must incorporate the use of these standards and procedures and must provide that certification decisions for ACDBEs will be made by the Unified Certification Program (UCP) in your state (see part 26,
following conditions apply:
(a) At the time of submission of the initial plan on January 26, 1992—
(1) The entity determines that it cannot meet all of the service criteria by January 26, 1997; or
(2) The entity determines that it cannot make measured progress toward compliance in any year before full compliance is required. For purposes of this part, measured progress means implementing milestones as