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- 26 CFR §1.245A(e)-1Special rules for hybrid dividends.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
trust (as described in section 856), or an S corporation (as described in section 1361). (3) The term person has the meaning provided in section
- 26 CFR §1.902-1Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
shareholder means a domestic corporation, other than an S corporation as defined in section 1361(a), that owns at least 10 percent of the voting stock of the foreign corporation
- 26 CFR §1.368-2Definition of terms.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
corporation that is a qualified subchapter S subsidiary (within the meaning of section 1361(b)(3)(B)). (B) Combining entity. A combining entity is a business entity that
- 26 CFR §1.411(d)-4Section 411(d)(6) protected benefits.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
after December 31, 1997, the employer is an S corporation as defined in section 1361. (iii) Employer securities become readily tradable. The employer eliminates, or retains the discretion to eliminate
- 26 CFR §1.56(g)-1Adjusted current earnings.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
applies to any corporation other than— (i) An S corporation as defined in section 1361, (ii) A regulated investment company as defined in section 851, (iii) A real estate investment
- 26 CFR §1.367(a)-3Treatment of transfers of stock or securities to foreign corporations.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
trusts (as defined in section 856(a)), and S corporations (as defined in section 1361(a)). (7) Gain subject to section 1248(a). If the U.S. transferor recognizes gain under
- 26 CFR §1.897-1Taxation of foreign investment in United States real property interests, definition of terms.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
REIT) as defined in section 856, or an S corporation as defined in section 1361. (B) A foreign-controlled domestic corporation is any non-public domestic C corporation if foreign
- 26 CFR §1.704-1Partner's distributive share.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
disregarded for Federal tax purposes, such as a qualified subchapter S subsidiary under section 1361(b)(3), an entity that is disregarded as an entity separate from its owner under