(a) General rule. If, in accordance with paragraph (d) of this section, it is established to the satisfaction of the district director that any amount of the earnings and profits of a controlled foreign corporation for the taxable year (determined under §1.964-1) was subject to a currency or other restriction or limitation imposed

corporation's taxable year, and then dividing that portion pro rata among the shares outstanding on that day. See paragraph (b) of this section for rules pertaining to the computation of each shareholder's pro rata share when an election is made under section 1377(a)(2) to treat the taxable year of an S corporation as if it consisted of two taxable years in the case of a termination of a shareholder's entire interest in the corporation. See

(A) by an employer engaged in commerce or in any industry or activity affecting commerce, or (B) by any employee organization, or organization representing employees, engaged in commerce or in any industry or activity affecting commerce, or (C) by both, which has, in practice, met the requirements of part I of subchapter D of chapter 1 of title 26 (as in effect for the preceding 5 plan

section 132(f)(5) of Title 26, Internal Revenue Code. Amendments 2002—Subsec. (a)(1). Pub. L. 107–296 substituted ", a member of a uniformed service, and a student who provides voluntary services under section 3111" for "and a member of a uniformed

debt instrument that is issued for nonpublicly traded property. Paragraph (d) of this section provides special rules for tax-exempt obligations. See §1.1275-6 for a taxpayer's treatment of a contingent payment debt instrument and a hedge. (2) Exceptions. This section does not apply to— (i) A

Accumulated taxable income for a taxable year consisting of a period of less than 12 months shall not be placed on an annual basis for the purpose of the accumulated earnings tax imposed by section 531. In such cases accumulated taxable income shall be computed on the basis of the taxable income for such period of less than 12 months, adjusted in the manner provided by section 535(b) and §1.535-2

(a) In order to be a bank as defined in section 581, an institution must be a corporation for federal tax purposes. See §301.7701-2(b) of this chapter for the definition of a corporation. (b) This section is effective as of January 1, 1997. [T.D. 8697, 61 FR 66588, Dec. 18, 1996]

In the case of a distribution by a partnership to a partner other than in liquidation of a partner's entire interest, the adjusted basis to such partner of his interest in the partnership shall be reduced (but not below zero) by the amount of any money distributed to such partner and by the amount of the basis to him of distributed property other than money as determined under section 732 and

Sections 1.951A-1 through 1.951A-6 apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. [T.D. 9866,

Under section 993(g), the term “United States” includes the States, the District of Columbia, the Commonwealth of Puerto Rico, and possessions of the United States. For the requirement that a DISC must be incorporated and existing under the laws of a State or the District of Columbia, see §1.992-1(a)(1). [T.D. 7514, 42 FR

For rules relating to returns required to be made by every individual, estate, or trust which is liable for one or more qualified State individual income taxes, as defined in section 6362, for a taxable year, see paragraph (b) of §301.6361-1 of this chapter (Regulations on procedure and Administration). [T.D. 7577, 43

Individual income tax returns that are required to be filed on magnetic media by tax return preparers under section 6011(e)(3) and §301.6011-7 of this chapter must be filed in accordance with Internal Revenue Service regulations, revenue procedures, revenue rulings, publications, forms or instructions, including those posted electronically.

(a) Proceeds of sale or indemnification. Deposits of amounts representing proceeds of the sale or indemnification for loss of a vessel or share therein must be made within 60 days after receipt by the taxpayer. (b) Earnings and receipts. Earnings and receipts for the taxable year may be deposited at any time. (See

An exemption of $60,000 is allowed as a deduction under section 2052 from the gross estate of a decedent who was a citizen or resident of the United States at the time of his death. For the amount of the exemption allowed as a deduction from the gross estate of a decedent who was a nonresident not a citizen of the United States, see paragraph (a)(3) of §20.2106-1.

Section 2202 provides that a duly commissioned missionary, dying while in foreign missionary service under a board of foreign missions of a religious denomination in the United States, is presumed to have retained a United States residence (see paragraph (b)(1) of §20.0-1) held at the time of his commission and departure for foreign service, in the absence of relevant facts other than his

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

Notwithstanding the provisions of §55.6091-1, the Commissioner may permit the filing of any Chapter 44 tax return in any local Internal Revenue Service office. [T.D. 7767, 46 FR 11282, Feb. 6, 1981; 46 FR 15263, Mar. 5, 1981. Redesignated by T.D. 8180, 53 FR 6148, Mar. 1, 1988, as amended by T.D. 9156, 69 FR 55746, Sept

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

(a) In general. For the definition of a tax return preparer, see §301.7701-15 of this chapter. (b) Effective/applicability date. This section is applicable to returns and claims for refund filed, and advice provided, after December 31, 2008.

The Secretary of the Navy shall have the general charge and superintendence of Navy hospitals. Editorial Notes Codification R.S. §4807 derived from acts Feb. 26, 1811, ch