108 resultados — página 3 de 6

• 26 CFR §1.172-5Taxable income which is subtracted from net operating loss to determine carryback or carryover.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  rule applicable to corporations which were electing small business corporations under Subchapter S (section 1361 and following), Chapter 1 of the Code, during one or more of the taxable years

• 26 CFR §1.1374-3Net unrealized built-in gain.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  limitation for 2009 is $50,000. Effective June 1, 2009, X elects under section 1361 to treat Y as a qualified subchapter S subsidiary (QSub). The election is treated

• 26 CFR §1.935-1Coordination of individual income taxes with Guam and the Northern Mariana Islands.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  eligibility of a corporation to make a subchapter S election (sections 1361 through 1379). Thus, for example, for purposes of determining whether a corporation created or organized in the relevant ... States, will not be treated as a nonresident alien individual for purposes of section 1361(b)(1)(C) of the Guam territorial income tax. (d) Special rules for estimated income

• 26 USC §512Unrelated business taxable income
  Federal (EE. UU.)Sección de códigoVigencia: 2024-12-31

  rules applicable to S corporations (1) In general If an organization described in section 1361(c)(2)(A)(vi) or 1361(c)(6) holds stock in an S corporation ... paragraph (1), the basis of any stock acquired by purchase (as defined in section 1361(e)(1)(C)) shall be reduced by the amount of any dividends received

• 26 CFR §1.6662-5Substantial and gross valuation misstatements under chapter 1.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  case of a corporation other than an S corporation (as defined in section 1361(a)(1)) or a personal holding company (as defined in section 542)). This limitation is applied

• 26 CFR §1.6417-1Elective payment election of applicable credits.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  Code. (m) S corporation. The term S corporation has the meaning provided in section 1361(a)(1) of the Code. (n) Section 6417 regulations. The term section 6417 regulations means

• 26 CFR §1.108(i)-1Deferred discharge of indebtedness income and deferred original issue discount deductions of C corporations.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  corporation as defined in section 1361(a)(1). (C) A qualified subchapter S subsidiary as defined in section 1361(b)(3)(B). (D) An entity operating on a cooperative basis

• 26 CFR §1.1291-1Taxation of U.S. persons that are shareholders of section 1291 funds.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  sections 1291 and 1298, a domestic partnership or S corporation (as defined in section 1361(a)(1)) is not treated as a shareholder of a PFIC except for purposes

• 26 CFR §1.179-2Limitations on amount subject to section 179 election.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  this section apply in the case of S corporations (as defined in section 1361(a)) and their shareholders. Each shareholder's share of the section 179 expenses ... this section apply in the case of S corporations (as defined in section 1361(a)) and their shareholders. Each shareholder's share of the taxable income of an S corporation

• 26 CFR §53.4968-3Related organizations.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  charitable remainder trust; (v) A partnership, S corporation (as defined in section 1361(a)(1) of the Code), or other pass-through entity that is generally not subject to Federal

• 26 CFR §1.1061-2Applicable partnership interests and applicable trades or businesses.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  Code (that is, a grantor trust), a qualified subchapter S subsidiary described in section 1361(b)(3), and an entity with a single owner that is treated as disregarded

• 26 CFR §1.932-1Coordination of United States and Virgin Islands income taxes.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  eligibility of a corporation to make a subchapter S election (sections 1361 through 1379). Thus, for example, for purposes of determining whether a corporation created or organized in the Virgin ... eligibility of a corporation to make a subchapter S election (mirrored sections 1361 through 1379). Thus, for example, for purposes of determining whether a corporation created or organized

• 26 CFR §1.367(d)-1Transfers of intangible property to foreign corporations.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  defined in section 992(a)(1)), or an S corporation (as defined in section 1361(a)); (C) A U.S. person that is an individual related, within the meaning of paragraph ... defined in section 992(a)(1)), or an S corporation (as defined in section 1361(a)). (iv) Qualified domestic person's basis in the intangible property. The qualified domestic person

• 26 CFR §1.860E-1Treatment of taxable income of a residual interest holder in excess of daily accruals.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  this section: (i) Eligible corporation means any domestic C corporation (as defined in section 1361(a)(2)) other than— (A) A corporation which is exempt from, or is not subject

• 26 CFR §1.6418-2Rules for making transfer elections.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  corporation for Federal income tax purposes (as defined in section 1361(a)(2) of the Code), qualifies as an eligible taxpayer and determines a section 45V clean hydrogen tax credit ... corporation for Federal income tax purposes (as defined in section 1361(a)(2) of the Code), qualifies as an eligible taxpayer and determines a section 45Y clean electricity production

• 26 CFR §1.6662-4Substantial understatement of income tax.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  case of a corporation other than an S corporation (as defined in section 1361(a)(1)) or a personal holding company (as defined in section 542)). (2) Understatement. Except ... pass-through entity is a partnership, S corporation (as defined in section 1361(a)(1)), estate, trust, regulated investment company (as defined in section 851(a)), real estate investment trust

• 26 CFR §1.645-1Election by certain revocable trusts to be treated as part of estate.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  aside deduction under section 642(c)(2), the subchapter S shareholder requirements of section 1361(b)(1), and the special offset for rental real estate activities in section ... aside deduction under section 642(c)(2), the subchapter S shareholder requirements of section 1361(b)(1), and the special offset for rental real estate activities under section

• 26 CFR §1.441-3Taxable year of a personal service corporation.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  year only if— (i) The taxpayer is a C corporation (as defined in section 1361(a)(2)) for the taxable year; (ii) The principal activity of the taxpayer during

• 26 CFR §1.334-1Basis of property received in liquidations.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  that has not elected to be an S corporation within the meaning of section 1361(a)(1); FC, CFC1, and CFC2 are controlled foreign corporations within the meaning of section

• 26 CFR §1.421-1Meaning and use of certain terms.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  purposes of the preceding sentence includes an S corporation (as defined in section 1361), a foreign corporation (as defined in section 7701(a)(5)), and a limited liability company that