(3) in the case of any amounts included in income under section 951(a)(1)(A) or 1293(a), the average exchange rate for the taxable year of the foreign corporation, or (4) in the case of any other qualified business unit of a taxpayer, the average exchange rate for the taxable year of such qualified business unit. For

(a) Distributions in complete liquidation treated as exchangesAmounts received by a shareholder in a distribution in complete liquidation of a corporation shall be treated as in full payment in exchange for the stock. (b) Nonapplication of section 301

materials used by the eligible educator in the classroom. (E) Certain expenses of members of reserve components of the Armed Forces of the United StatesThe deductions allowed by section 162 which consist of expenses, determined at a rate not in excess of the rates for travel expenses (including per diem in lieu of subsistence) authorized for employees of

(A) Coordination with treatiesTo the extent required under any treaty obligation of the United States, the credit allowed under this subsection shall be equal to the amount which bears the same ratio to the applicable credit amount in effect under section 2010(c) for the calendar year which includes the date of death as the value of the part of

Except as otherwise provided in section 4263(a), every person receiving any payment for facilities or services on which a tax is imposed upon the payor thereof under this chapter shall collect the amount of the tax from the person making such payment.

stated orally and recorded in the transcript of the proceedings. (c) Date of decisionA decision of the Tax Court (except a decision dismissing a proceeding for lack of jurisdiction) shall be held to be rendered upon the date that an order specifying the amount of the deficiency is entered in the records of the Tax Court or, in the case of a declaratory judgment proceeding under part IV of this subchapter or under

(A) $7,000, or (B) an amount equal to 25 percent of the compensation (as defined in section 415(c)(3)) includible in the individual's gross income for such taxable year. (4) Special rule for simple retirement accountsThis section shall not apply with respect to any amount contributed to a simple retirement

§ 222.5 Water control management (ER 1110–2–240). (a) Purpose. This regulation prescribes policies and procedures to be followed by the U.S. Army Corps of Engineers in carrying out water control management activities, including establishment of water control plans for Corps and non-Corps projects

(a) General ruleIn the case of a nonresident alien individual, the deductions shall be allowed only for purposes of section 871(b) and (except as provided by subsection (b)) only if and to the extent that they are connected with income which is effectively connected with the conduct of a trade or business within the United States; and

(a) Requirement—(1) In general: after 1983 and before April 1, 1991. In the case of a calendar month which begins after December 31, 1983, and before April 1, 1991, if, at a time prescribed under §31.6302(c)-1(a)(1) (i) or (v) for the deposit of undeposited taxes, the aggregate

(a) Pension plan contractsFor purposes of this part, the term "pension plan contract" means any contract— (1) entered into with trusts which (as of the time the contracts were entered into) were deemed to be trusts described in section 401(a) and exempt from tax under

p.m. to CC:PA:LPD:PR (REG-105495-19), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC 20224. FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations under §§ 1.861-8, 1.861-9(b), 1.861-12, 1.861-14, 1.861-17, and 1.954

section 6213(a) (or 7481(c) with respect to a determination of statutory interest or section 7481(d) solely with respect to a determination of estate tax by the Tax Court), no credit or refund of income tax for the same taxable year, of gift tax for the same calendar year or calendar quarter, of estate tax in respect of the taxable estate of the same

(a) General rule (1) Gains exceed lossesIf— (A) the section 1231 gains for any taxable year, exceed (B) the section 1231

(a) TaxExcept as provided in sections 6015(e), 6212(a) and (c), 6213(a), 6232(c), 6330(e)(1), 6331(i), 6672(c), 6694(c), 7426(a) and (b)(1), 7429(b), and 7436, no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against

(a) State and local governmental exemptionUnder regulations prescribed by the Secretary, no tax shall be imposed by section 4481 on the use of any highway motor vehicle by any State or any political subdivision of a State. (b) Exemption for United StatesThe Secretary of the Treasury

) references to empowerment zones were substituted for references to renewal communities, (ii) references to enterprise zone businesses (as defined in section 1397C) were substituted for references to renewal community businesses, (iii) the date of the enactment of this paragraph were substituted for "December 31, 2001" each place

section 40A(d)(1)) or alcohol (as defined in section 6426(b)(4)(A)), every person producing or importing sustainable aviation fuel (as defined in section 40B), every person producing a fuel eligible for the clean fuel production credit (pursuant to

(a) GasolineExcept as provided in subsection (g), if gasoline is used on a farm for farming purposes, the Secretary shall pay (without interest) to the ultimate purchaser of such gasoline the amount determined by multiplying— (1) the number of gallons so used, by (2) the rate of tax on gasoline under

For termination of extensions of time for payment of income tax granted to corporations expecting carrybacks in case of jeopardy, see section 6164(h).

(a) Rail employerFor purposes of this chapter, the term "rail employer" means any person who is an employer as defined in section 1 of the Railroad Unemployment Insurance Act. (b) Rail wagesFor purposes of this chapter, the term "rail wages" means, with respect to any calendar month, so

Gross income includes— (1) the amount of the alcohol fuel credit determined with respect to the taxpayer for the taxable year under section 40(a), (2) the biodiesel fuels credit determined with respect to the taxpayer for the taxable year under

(1) For special provisions relating to foreign corporations carrying on an insurance business within the United States, see section 842. (2) For rules applicable in determining whether any foreign corporation is engaged in trade or business within the United States, see

(a) In general. A person who is a tax return preparer of any return or claim for refund of excise tax under section 4481 shall be subject to penalties under section 6694(a) in the manner stated in §1.6694-2 of this chapter. (b) Effective/applicability date.

(a) In general. A person who is a tax return preparer of any return or claim for refund of tax on wagers under sections 4401 or 4411 shall be subject to penalties under section 6694(a) in the manner stated in §1.6694-2 of this chapter. (b) Effective/applicability

taxpayers shall not exceed $2,000. For this purpose, joint tenants with right of survivorship are treated as equal owners. For an example of the operation of this provision see Example (2) of §1.44-5(b)(2)(ii). (5) Application with other credits. The credit allowed by this section shall not