the close of the day of distribution or transfer, the items described in subsection (c) of the distributor or transferor corporation, subject to the conditions and limitations specified in subsections (b) and (c). For purposes of the preceding sentence, a reorganization shall be treated as meeting the requirements of subparagraph (D) or (G) of section 368(a)(1) only if the requirements of subparagraphs

Secretary determines to be liable for such tax. (B) Check or money order not duly paidIn any case in which a check or money order received under authority of section 6311 as payment for stamps is not duly paid, the unpaid amount may be immediately assessed as if it were a tax imposed by this title, due at the time of such receipt, from the person who

(a) In general. Except as provided in paragraph (b) of this section, the term dividend for purposes of this section and §§1.6042-2 and 1.6042-4 means the amounts described in the following paragraphs (a) (1) through (3) of this section— (1) Any distribution

if the qualified security had been sold to the employee at fair market value. (c) Liability for payment of taxesThe tax imposed by this subsection shall be paid by— (1) the employer, or (2) the eligible worker-owned cooperative, that made the written statement described in

(a) General ruleUnder regulations prescribed by the Secretary, in the case of a United States shareholder who is an individual and who elects to have the provisions of this section apply for the taxable year— (1) the tax imposed under this chapter on amounts which are included in his gross income under

For purposes of this section, an adoption assistance program is a separate written plan of an employer for the exclusive benefit of such employer's employees— (1) under which the employer provides such employees with adoption assistance, and (2) which meets requirements similar to the requirements of paragraphs (2), (3), (5), and (6) of

) dividends other than those derived from sources within the United States as provided in section 861(a)(2); (3) compensation for labor or personal services performed without the United States; (4) rentals or royalties from property located without the United States or from any interest in such property, including rentals or royalties for the

(a) Open taxable years. (1) For purposes of paragraph (a) of §1.981-1, and paragraph (a) of §1.981-2, a taxable year of the U.S. citizen, and the taxable year or years of his nonresident alien

may establish amount allowedFor purposes of subparagraph (A), if the taxpayer can establish by adequate records or other sufficient evidence that the amount allowed for depreciation or amortization for any period was less than the amount allowable, the amount added for such period shall be the amount allowed. (C) Certain deductions treated as amortizationAny deduction allowable under

(a) General ruleNo deduction shall be allowed for the following taxes: (1) Federal income taxes, including— (A) the tax imposed by section 3101 (relating to the tax on employees under the Federal Insurance Contributions Act);

. For infrastructure items that would be used to connect specific end users, those items may be used to connect individual Cubans or the Cuban private sector only (e.g., not Cuban government ministries or state-owned enterprises). (2) The export or reexport to Cuba of items for use by news media personnel engaged in the gathering and dissemination of news to the general public and who are: (i

to be eligible, and shall be addressed to the Director General of the Foreign Service, Department of State, Washington, DC 20520. Applications may be filed within 60 days after the latest of: a declaration under §192.1(a), the hostile action, or release from captivity. Later filing may be considered when in the opinion of the Secretary of State there is good cause for the late filing. Applications in

(a) In general (1) 1-year carryback and 20-year carryforwardIf the sum of the business credit carryforwards to the taxable year plus the amount of the current year business credit for the taxable year exceeds the amount of the limitation imposed by subsection (c) of section 38 for such

If the foreign law imposing a FORI tax (as defined in §1.907(c)-3) is either structured in a manner, or operates in a manner, so that the amount of tax imposed on FORI is generally materially greater than the tax imposed by the foreign law on income that is neither FORI nor FOGEI (“described manner”), section 907(b) provides a special rule which limits the

(2) $10. (b) Excessive amount definedFor purposes of this section, the term "excessive amount" means in the case of any person the amount by which— (1) the amount claimed under section 6416(a)(4), 6420, 6421, 6427, or 6435, as the case may be, for any period, exceeds (2

(a) Application of tax (1) Charitable trustsFor purposes of part II of subchapter F of chapter 1 (other than section 508(a), (b), and (c)) and for purposes of this chapter, a trust which is not exempt from taxation under

(a) Time for filing petition and restriction on assessmentWithin 90 days, or 150 days if the notice is addressed to a person outside the United States, after the notice of deficiency authorized in section 6212 is mailed (not counting Saturday, Sunday, or a legal holiday in the District of Columbia as the last day), the taxpayer may

which is required by section 807(b) to be taken into account under this paragraph. (3) Policyholder dividendsThe deduction for policyholder dividends (determined under section 808(c)). (4) Dividends received by

(a) DefinitionFor purposes of this subtitle, the term "accumulated taxable income" means the taxable income, adjusted in the manner provided in subsection (b), minus the sum of the dividends paid deduction (as defined in section 561) and the accumulated earnings credit (as defined in subsection (c)).

(2) a tentative tax computed under section 2001(c) on the amount of the adjusted taxable gifts. (c) Adjustments for taxable gifts (1) Adjusted taxable gifts definedFor purposes of this section, the term "adjusted taxable gifts" means the total amount of the taxable

(a) Returns and return information (1) Federal employees and other personsIt shall be unlawful for any officer or employee of the United States or any person described in section 6103(n) (or an officer or employee of any such person), or any former officer or employee, willfully to

(a) Inspection of applications for tax exemption or notice of status (1) Public inspection (A) Organizations described in section 501 or 527If an organization described in

section 117(a) applies, but only to the extent includible in gross income; or (2) in the case of an individual who is not a candidate for a degree at an educational organization described in section 170(b)(1)(A)(ii), granted by— (A) an organization described in

(a) General ruleUnder regulations prescribed by the Secretary, no tax shall be imposed under this chapter (other than under section 4121 or 4081) on the sale by the manufacturer (or under subchapter C of chapter 31 on the first retail sale) of an article— (1) for use by the purchaser for further

(a) For exemption of— (1) Allowances and expenditures to meet losses sustained by persons serving the United States abroad, due to appreciation of foreign currencies, see section 5943 of title 5, United States Code. (2) Benefits under laws administered by the Department of Veterans Affairs, see

(a) Jurisdiction (1) In generalThe United States Courts of Appeals (other than the United States Court of Appeals for the Federal Circuit) shall have exclusive jurisdiction to review the decisions of the Tax Court, except as provided in section 1254 of Title 28 of the United States Code

determine its market value based on her observation that a comparable watch, not inscribed with a logo, generally sells for about $50. Example 2 to paragraph (c): During an official visit to a factory operated by a well-known athletic footwear manufacturer, an employee of the Department of Labor is offered a commemorative pair of athletic shoes manufactured at the

generalEvery trust not required to file a return under subsection (a) but claiming a deduction under section 642(c) for the taxable year shall furnish such information with respect to such taxable year as the Secretary may by forms or regulations prescribe, including— (A) the amount of the deduction taken under