§1.960-2(b). In Year 2, CFC distributes the entire $80x of Year 1 previously taxed earnings and profits, from which a foreign income tax of $8x is withheld. Also in Year 2, CFC pays $40x of interest to USP, from which a foreign income tax of $4x is withheld. For Year 2, USP chooses to claim deductions for its creditable foreign income taxes under section 164 rather than a foreign tax credit under section 901.

film. Under section 992(e), if such produced film rents are included in the ordinary gross income (as defined in section 543(b)(1)) of a qualified subsidiary for a taxable year of such subsidiary, and such interest was acquired by such subsidiary from its parent, such interest is deemed (for purposes of the application of sections 541, 543(b)(1), and 992(d)(2), and §1.992-1(f) for such taxable year

(a) By the corporation—(1) Mandatory records. A plan to issue pre-November 1978 stock must appear upon the records of the corporation. Any designation of post-November 1978 stock under §1.1244(c)-2(b)(2) also must appear upon the records of the corporation.

which this section does not apply, corporations and shareholders subject to the provisions of section 1363 must take reasonable return positions taking into consideration the statute, its legislative history and these regulations. See Notice 92-56, 1992-49 I.R.B. (see §601.601(d)(2)(ii)(b) of this chapter), for additional guidance regarding reasonable return

shown on the Form 7004 or to the REMIC's last known address. For further guidance regarding the definition of last known address, see §301.6212-2 of this chapter. (f) Penalties. See sections 6698 and 6651 for failure to file a REMIC income tax return or failure to pay an amount shown as tax on the return.

provided in paragraph (b)(2) of §301.6091-1 of this chapter (relating to hand-carried documents), the application on Form 4466 shall be filed with the internal revenue officer designated in instructions applicable to such form. [T.D. 7059, 35 FR 14546, Sept. 17, 1970]

§15.1-1. Such an election may not be revoked after the expiration of the 3-year period. (2) Election under section 617(a). An election under section 617(a) may be revoked before the expiration of the last day of the third month following the month in which the final regulations issued under the authority of section 617 are published in the

, see §20.2056A-1(b)) at all times after the death of the decedent and before becoming a United States citizen, or no taxable distributions are made from the QDOT before the spouse becomes a United States citizen (regardless of the residency status of the spouse); and (2) The U.S. Trustee(s) of the QDOT notifies the Internal Revenue Service and certifies in writing

2101(b) and (c). For the meaning of the terms resident, nonresident, and United States, as applied to a decedent for purposes of the estate tax, see §20.0-1(b)(1) and (2). For the liability of the executor for the payment of the tax, see section 2002. For special rules as to the phaseout of the graduated rates and unified

governing instrument requirements of section 508(e) (determined without regard to section 508(e)(2) (B) and (C)), or (2) Any organization in a period for which it is not treated as an organization described in section 501(c)(3) by reason of its failure to give notification under section 508(a) of its status to the Commissioner. For additional rules, see

employer ordinarily pays the employee remuneration solely by way of cash commissions for services performed by him as a retail commission salesman. (2) Section 3402(j) and this section are not applicable with respect to wages paid to the employee that are subject to withholding under §31.3402(g)-1(a)(2). Section 3402(j) and this section are not applicable with

Additional withholding permitted. Consistent with the provisions of section 3402(p), a tribal member and a tribe may enter into an agreement to provide for the deduction and withholding of additional amounts from payments in order to satisfy the anticipated tax liability of the tribal member. The agreement may be made in a manner similar to that described in §31.3402(p)-1 (with

betting pool or lottery for profit, he shall, notwithstanding such lay-off, be liable for the tax on the wagers or contributions initially accepted by him. See §44.6419-2 for credit and refund provisions applicable with respect to laid-off wagers.

administrator, or other legal representative of the deceased taxpayer continues the business, such person shall within 30 days after the date of the death of the taxpayer execute a return on Form 11-C. Such return shall show the name of the deceased taxpayer, together with all other data required to be reported on Form 11-C (see §44.4412-1), and the stamp issued to such taxpayer shall be submitted with the

) applies to: (i) Arm's-length sales at retail or on consignment, other than those sales at retail and to retailers to which section 4216(b)(2) and §48.4216(b)-3 apply; and (ii) Sales otherwise than at arm's length, and at less than fair market price. (2) Section 4216(b)(2) applies generally

cover all sales by the seller to the purchaser made during a designated period not to exceed 12 successive calendar quarters.”. See paragraph (c) of §48.4221-1 for the evidence required to establish exemption. [T.D. 7536, 43 FR 13522, Mar. 31, 1978, as amended by T.D. 7686, 45 FR 17574, Mar. 19, 1980; T.D. 8036, 50 FR 29963, July 23, 1985]

considered a price readjustment constituting an overpayment which the manufacturer may claim as a credit or refund. The amount of the reimbursement may not, however, exceed the limitation provided by section 4216(e)(2) and §48.4216(e)-2, determined as of the close of the calendar quarter in which the reimbursement is made or as of the close of any subsequent calendar quarter of the same calendar

determination of the appraised value of the property, which notice shall be confirmed in writing prior to sale. The property shall be returned to the owner if, within the time specified in the notice, the owner— (1) Pays to the district director an amount equal to the appraised value, or (2) Gives an acceptable bond as prescribed by section 7101 and

§301.6871(a)-1 to make immediate assessment of any deficiency, such assessment is not made as a jeopardy assessment within the meaning of section 6861, and consequently the provisions of that section do not apply to any assessment made under section 6871. Therefore, the notice of deficiency provided in section 6861(b) will not be mailed. Although such notice will not be issued, a letter will be sent to the

corresponding provision of the Internal Revenue Code of 1939, or any prior revenue law, is not required to renew such license under this section. (f) Returns of information as to foreign items. For provisions relating to the filing of returns as to foreign items, see section 6041(b) and §1.6041-4 of this chapter (Income Tax Regulations

procedures include, but are not limited to, those relating to: procedures pursuant to §601.702(d) of this chapter; Freedom of Information Act requests pursuant to 5 U.S.C. 552; Privacy Act of 1974 requests pursuant to 5

persons as disclosed on such return, together with ownership certificate, Form 1001-D, filed in connection with coupon bond interest. Such transmission shall constitute compliance with Article XVII of the convention and of §§521.101 to 521.117. (c) Information in specific cases. Under the provisions and limitations of Article XVII

incompatible with the procedure under the other Code. Reference to sections of the Code are references to the Internal Revenue Code of 1954, unless otherwise expressly indicated. (b) Scope. This part sets forth the procedural rules of the Internal Revenue Service respecting all taxes administered by the Service, and supersedes the previously published statement (26 CFR (1949 ed., Part 300-End) Parts 600 and 601) with respect to such

. No. 5084, 29 FR 16150, Dec. 3, 1964, as amended by Amdt. 29-3, 33 FR 969, Jan. 26, 1968; Amdt. 29-24, 49 FR 44438, Nov. 6, 1984; Amdt. 27-26, 55 FR 8004, Mar. 6, 1990]

the best quantitative and qualitative social science research methods available, containing an estimate of the incidence and prevalence of runaway and homeless individuals who are not less than 13 years of age but are less than 26 years of age; and (2) that includes with such estimate an assessment of the characteristics of such individuals. (b) ContentThe report required by subsection (a) shall include—

section 412 of title 26 and reasonable estimates for the interim years of the unfunded vested benefits, and (2) in the absence of complete data, rely on the data available or on data secured by a sampling which can reasonably be expected to be representative of the status of the entire plan. (c) Determination of amount of unfunded vested benefitsFor purposes of this part, the term "unfunded vested benefits" means

The Secretary of the Interior is authorized, in his discretion, to examine and classify any lands withdrawn or reserved by Executive order of November 26, 1934 (numbered 6910), and amendments thereto, and Executive order of February 5, 1935 (numbered 6964), or within a grazing district, which are more valuable or suitable for the production of agricultural crops than for the production of native grasses and forage plants, or more valuable or

1978—Pub. L. 95–578 substituted "November 2, 1978" for "September 30, 1968". Termination of National Water Commission National Water Commission, established by Pub. L. 90–515, Sept. 26, 1968, 82 Stat. 868, terminated Sept. 26, 1973.

A prior section 1774, Pub. L. 89–642, §5, Oct. 11, 1966, 80 Stat. 887; Pub. L. 91–248, §2, May 14, 1970, 84 Stat. 208; Pub. L. 92–433, §6(a)–(d), Sept. 26, 1972, 86 Stat. 727; Pub. L. 93–326, §5, June 30, 1974, 88 Stat. 287; Pub. L. 94–105, §18, Oct. 7, 1975, 89 Stat. 525; Pub. L. 95–166, §§4, 20(3), (4), Nov. 10, 1977, 91 Stat. 1332, 1346; Pub. L. 95–627, §6(b), Nov. 10, 1978

. Cincinnati, Columbus, Dayton Group (CCD)—Cincinnati Gas and Electric Company, Columbus and Southern Ohio Electric Company, Dayton Power and Light Company. 15. Kentucky Group—19. 16. Indiana Group—Indiana Utilities except AEP. 17. Illinois—Missouri Group (ILLMO)—15, 40. 18. Michigan Electric Coordinated Systems (MECS)—11. 19. Wisconsin—Upper Michigan Group (WUMS)—13. 20. Mid-Continent Area Power Pool (MAAP)—16, 17, 26, 27, 28. 21. Missouri—Kansas Group