Code of Federal Regulations · Section
§ 1.1441-0 — -0 Outline Of Regulation Provisions For Section 1441
26 C.F.R. § 1.1441-0
This section lists captions contained in §§ 1.1441-1 through 1.1441-9.
(a) Purpose and scope.
(b) General rules of withholding.
(1) Requirement to withhold on payments to foreign persons.
(2) Determination of payee and payee's status.
(i) In general.
(ii) Payments to a U.S. agent of a foreign person.
(iii) Payments to wholly-owned entities.
(A) Foreign-owned domestic entity.
(B) Foreign entity.
(iv) Payments to a U.S. branch of certain foreign banks or foreign insurance companies.
(A) U.S. branch treated as a U.S. person in certain cases.
(B) Consequences to the withholding agent.
(C) Consequences to the U.S. branch.
(D) Definition of payment to a U.S. branch.
(E) Payments to other U.S. branches.
(v) Payments to a foreign intermediary.
(A) Payments treated as made to persons for whom the intermediary collects the payment.
(B) Payments treated as made to foreign intermediary.
(vi) Other payees.
(vii) Rules for reliably associating a payment with a withholding certificate or other appropriate documentation.
(A) Generally.
(B) Special rules applicable to a withholding certificate from a nonqualified intermediary or flow-through entity.
(C) Special rules applicable to a withholding certificate provided by a qualified intermediary that does not assume primary withholding responsibility.
(D) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary withholding responsibility under chapter 3 and chapter 4 of the Internal Revenue Code.
(E) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary Form 1099 reporting and backup withholding responsibility but not primary withholding under chapter 3 and chapter 4.
(F) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary withholding responsibility under chapter 3 and chapter 4 and primary Form 1099 reporting and backup withholding responsibility and a withholding certificate provided by a withholding foreign partnership or a withholding foreign trust.
(3) Presumptions regarding payee's status in the absence of documentation.
(i) General rules.
(ii) Presumptions of classification as individual, corporation, partnership, etc.
(A) In general.
(B) No documentation provided.
(C) Documentary evidence furnished for offshore obligation.
(iii) Presumption of U.S. or foreign status.
(A) Payments to exempt recipients.
(1) In general.
(2) Special rule for withholdable payments made to exempt recipients.
(B) Scholarships and grants.
(C) Pensions, annuities, etc.
(D) Payments with respect to offshore obligations.
(E) Certain payments for services.
(iv) Grace period.
(v) Special rules applicable to payments to foreign intermediaries.
(A) Reliance on claim of status as foreign intermediary.
(B) Beneficial owner documentation or allocation information is lacking or unreliable.
(vi) U.S. branches and territory financial institutions not treated as U.S. persons.
(vii) Joint payees.
(A) In general.
(B) Special rule for offshore obligations.
(viii) Rebuttal of presumptions.
(ix) Effect of reliance on presumptions and of actual knowledge or reason to know otherwise.
(A) General rule.
(B) Actual knowledge or reason to know that amount of withholding is greater than is required under the presumptions or that reporting of the payment is required.
(x) Examples.
(4) List of exemptions from, or reduced rates of, withholding under chapter 3 of the Code.
(5) Establishing foreign status under applicable provisions of chapter 61 of the Code.
(6) Rules of withholding for payments by a foreign intermediary or certain U.S. branches.
(i) In general.
(ii) Examples.
(7) Liability for failure to obtain documentation timely or to act in accordance with applicable presumptions.
(i) General rule.
(ii) Proof that tax liability has been satisfied.
(A) In general.
(B) Special rule for establishing that income is effectively connected with the conduct of a U.S. trade or business.
(iii) Liability for interest and penalties.
(iv) Special rule for determining validity of withholding certificate containing inconsequential errors.
(v) Special effective date.
(8) Adjustments, refunds, or credits of overwithheld amounts.
(9) Payments to joint owners.
(c) Definitions.
(1) Withholding.
(2) Foreign and U.S. person.
(i) In general.
(ii) Dual residents.
(3) Individual.
(i) Alien individual.
(ii) Nonresident alien individual.
(4) Certain foreign corporations.
(5) Financial institution and foreign financial institution (or FFI).
(6) Beneficial owner.
(i) General rule.
(ii) Special rules.
(A) General rule.
(B) Foreign partnerships.
(C) Foreign simple trusts and foreign grantor trusts.
(D) Other foreign trusts and foreign estates.
(7) Withholding agent.
(8) Person.
(9) Source of income.
(10) Chapter 3 of the Code (or chapter 3).
(11) Reduced rate.
(12) Payee.
(13) Intermediary.
(14) Nonqualified intermediary.
(15) Qualified intermediary.
(16) Withholding certificate.
(17) Documentary evidence; other appropriate documentation.
(18) Documentation.
(19) Payor.
(20) Exempt recipient.
(21) Non-exempt recipient.
(22) Reportable amounts.
(23) Flow-through entity.
(24) Foreign simple trust.
(25) Foreign complex trust.
(26) Foreign grantor trust.
(27) Partnership.
(28) Nonwithholding foreign partnership (or NWP).
(29) Withholding foreign partnership (or WP).
(30) Possession of the United States or U.S. territory.
(31) Amount subject to chapter 3 withholding.
(32) EIN.
(33) Flow-through withholding certificate.
(34) Foreign payee.
(35) Intermediary withholding certificate.
(36) Nonwithholding foreign trust (or NWT).
(37) Payment with respect to an offshore obligation.
(38) Permanent residence address.
(i) In general.
(ii) Hold mail instruction.
(39) Standing instructions to pay amounts.
(40) Territory financial institution.
(41) TIN.
(42) Withholding foreign trust (or WT).
(43) Certified deemed-compliant FFI.
(44) Chapter 3 withholding rate pool.
(45) Chapter 3 status.
(46) Chapter 4 of the Code (or chapter 4).
(47) Chapter 4 status.
(48) Chapter 4 withholding rate pool.
(49) Deemed-compliant FFI.
(50) GIIN (or Global Intermediary Identification Number).
(51) NFFE.
(52) Nonparticipating FFI.
(53) Participating FFI.
(54) Preexisting obligation.
(55) Registered deemed-compliant FFI.
(56) Withholdable payment.
(d) Beneficial owner's or payee's claim of U.S. status.
(1) In general.
(2) Payments for which a Form W-9 is otherwise required.
(3) Payments for which a Form W-9 is not otherwise required.
(4) When a payment to an intermediary or flow-through entity may be treated as made to a U.S. payee.
(e) Beneficial owner's claim of foreign status.
(1) Withholding agent's reliance.
(i) In general.
(ii) Payments that a withholding agent may treat as made to a foreign person that is a beneficial owner.
(A) General rule.
(B) Additional requirements.
(2) Beneficial owner withholding certificate.
(i) In general.
(ii) Requirements for validity of certificate.
(A) In general.
(B) Requirement to collect foreign TIN and date of birth.
(1) In general.
(2) Definitions.
(3) Requirements for reasonable explanation of the absence of a foreign TIN.
(4) Exceptions to the requirement to obtain a foreign TIN (or reasonable explanation for its absence).
(i) Jurisdictions with which the United States does not have an agreement relating to the exchange of tax information.
(ii) Jurisdictions that do not issue foreign TINs.
(iii) Account holder that is a government, international organization, foreign central bank of issue, or resident of a U.S. territory.
(5) Transition rules for the foreign TIN requirement for a beneficial owner withholding certificate signed before January 1, 2018.
(i) Payments made before January 1, 2020.
(ii) Payments made after December 31, 2019.
(iii) Limitation on standard of knowledge.
(6) Transition rule for the date of birth requirement for a beneficial owner withholding certificate signed before January 1, 2018.
(3) Intermediary, flow-through, or U.S. branch withholding certificate.
(i) In general.
(ii) Intermediary withholding certificate from a qualified intermediary.
(iii) Intermediary withholding certificate from a nonqualified intermediary.
(iv) Withholding statement provided by nonqualified intermediary.
(A) In general.
(B) General requirements.
(C) Content of withholding statement.
(1) In general.
(2) Nonqualified intermediary withholding statement for withholdable payments.
(3) Alternative withholding statement.
(4) Example.
(D) Alternative procedures.
(1) In general.
(2) Withholding rate pools.
(i) In general.
(ii) Withholding rate pools for .chapter 4 purposes.
(3) Allocation information.
(4) Failure to provide allocation information.
(5) Cure provision.
(6) Form 1042-S reporting in case of allocation failure.
(7) Liability for tax, interest, and penalties.
(8) Applicability to flow-through entities and certain U.S. branches.
(E) Notice procedures.
(v) Withholding certificate from certain U.S. branches (including territory financial institutions).
(vi) Reportable amounts.
(4) Applicable rules.
(i) Who may sign the certificate.
(A) In general.
(B) Electronic signatures.
(ii) Period of validity.
(A) General rule.
(1) Withholding certificates and documentary evidence.
(2) Documentary evidence for treaty claims and treaty statements.
(B) Indefinite validity period.
(C) Withholding certificate for effectively connected income.
(D) Change in circumstances.
(1) Defined.
(2) Obligation to notify a withholding agent of a change in circumstances.
(3) Withholding agent's obligation with respect to a change in circumstances.
(iii) Retention of documentation.
(iv) Electronic transmission of information.
(A) In general.
(B) Requirements.
(1) In general.
(2) Same information as paper Form W-8.
(3) Perjury statement and signature requirements.
(i) Perjury statement.
(ii) Electronic signature.
(4) Requests for electronic Form W-8 data.
(C) Form 8233.
(D) Forms and documentary evidence received by facsimile or email.
(E) Third party repositories.
(F) Examples.
(1) Example 1.
(2) Example 2.
(3) Example 3.
(v) Additional procedures for certificates provided electronically.
(vi) Acceptable substitute form.
(vii) Requirement of taxpayer identifying number.
(viii) Reliance rules.
(A) Classification.
(B) Status of payee as an intermediary or as a person acting for its own account.
(C) Reliance on a prior version of a withholding certificate.
(ix) Certificates to be furnished to withholding agent for each obligation unless exception applies.
(A) Exception for certain branch or account systems or system maintained by agent.
(B) Reliance on certification provided by introducing brokers.
(1) In general.
(2) Example.
(C) Reliance on documentation and certifications provided between principals and agents.
(1) Withholding agent as agent.
(2) Withholding agent as principal.
(D) Reliance upon documentation for accounts acquired in merger or bulk acquisition for value.
(5) Qualified intermediaries.
(i) In general.
(ii) Definition of qualified intermediary.
(iii) Withholding agreement.
(A) In general.
(B) Terms of the withholding agreement.
(iv) Assignment of primary withholding responsibility.
(v) Withholding statement.
(A) In general.
(B) Content of withholding statement.
(C) Withholding rate pools.
(1) In general.
(2) Withholding rate pool requirements for a withholdable payment.
(3) Alternative procedure for U.S. non-exempt recipients.
(D) Example.
(6) Qualified derivatives dealers.
(f) Effective/applicability date.
(1) In general.
(2) Lack of documentation for past years.
(3) Special rules related to section 871(m).
(a) In general.
(b) Fixed or determinable annual or periodical income.
(1) In general.
(i) Definition.
(ii) Manner of payment.
(iii) Determinability of amount.
(2) Exceptions.
(3) Original issue discount.
(i) Amount subject to tax.
(ii) Amounts subject to withholding.
(iii) Exceptions to withholding.
(4) Securities lending transactions and equivalent transactions.
(5) REMIC residual interests.
(6) Dividend equivalents.
(c) Other income subject to withholding.
(d) Exceptions to withholding where no money or property is paid or lack of knowledge.
(1) General rule.
(2) Cancellation of debt.
(3) Satisfaction of liability following underwithholding by withholding agent.
(4) Withholding exemption inapplicable.
(e) Payment.
(1) General rule.
(2) Income allocated under section 482.
(3) Blocked income.
(4) Special rules for dividends.
(5) Certain interest accrued by a foreign corporation.
(6) Payments other than in U.S. dollars.
(7) Payments of dividend equivalents.
(i) In general.
(ii) Payment.
(iii) Premiums and other upfront payments.
(f) Effective/applicability date.
(a) General rule.
(1) Withholding on gross amount.
(2) Coordination with chapter 4.
(b) Withholding on payments on certain obligations.
(1) Withholding at time of payment of interest.
(2) No withholding between interest payment dates.
(i) In general.
(ii) Anti-abuse rule.
(c) Corporate distributions.
(1) General rule.
(2) Exception to withholding on distributions.
(i) In general.
(ii) Reasonable estimate of accumulated and current earnings and profits on the date of payment.
(A) General rule.
(B) Procedures in case of underwithholding.
(C) Reliance by intermediary on reasonable estimate.
(D) Example.
(3) Special rules in the case of distributions from a regulated investment company.
(i) General rule
(ii) Reliance by intermediary on reasonable estimate.
(4) Coordination with withholding under section 1445.
(i) In general.
(A) Withholding under section 1441.
(B) Withholding under both sections 1441 and 1445.
(C) Coordination with REIT/QIE withholding.
(ii) Intermediary reliance rule.
(d) Withholding on payments that include an undetermined amount of income.
(1) In general.
(2) Withholding on certain gains.
(e) Payments other than in U.S. dollars.
(1) In general.
(2) Payments in foreign currency.
(f) Tax liability of beneficial owner satisfied by withholding agent.
(1) General rule.
(2) Example.
(g) Conduit financing arrangements
(1) Duty to withhold.
(2) Effective date.
(h) Dividend equivalents.
(1) Withholding on gross amount.
(2) Reliance by withholding agent on reasonable determinations.
(3) Effective/applicability date.
(i) Effective/applicability date.
(a) Certain income connected with a U.S. trade or business.
(1) In general.
(2) Withholding agent's reliance on a claim of effectively connected income.
(i) In general.
(ii) Special rules for U.S. branches of foreign persons.
(A) U.S. branches of certain foreign banks or foreign insurance companies.
(B) Other U.S. branches.
(3) Income on notional principal contracts.
(i) General rule.
(ii) Exception for certain payments.
(iii) Exception for specified notional principal contracts.
(b) Compensation for personal services of an individual.
(1) Exemption from withholding.
(2) Manner of obtaining withholding exemption under tax treaty.
(i) In general.
(ii) Withholding certificate claiming withholding exemption.
(iii) Review by withholding agent.
(iv) Acceptance by withholding agent.
(v) Copies of Form 8233.
(3) Withholding agreements.
(4) Final payment exemption.
(5) Requirement of return.
(6) Personal exemption.
(i) In general.
(ii) Multiple exemptions.
(iii) Special rule where both certain scholarship and compensation income are received.
(c) Special rules for scholarship and fellowship income.
(1) In general.
(2) Alternate withholding election.
(d) Annuities received under qualified plans.
(e) Per diem of certain alien trainees.
(f) Failure to receive withholding certificates timely or to act in accordance with applicable presumptions.
(g) Effective/applicability date.
(a) In general.
(b) Rules applicable to U.S. partnerships, trusts, and estates.
(1) Payments to U.S. partnerships, trusts, and estates.
(2) Withholding by U.S. payees.
(i) U.S. partnerships.
(A) In general.
(B) Effectively connected income of partners.
(ii) U.S. simple trusts.
(iii) U.S. complex trusts and U.S. estates.
(iv) U.S. grantor trusts.
(v) Subsequent distribution.
(vi) Coordination with chapter 4 requirements for U.S. partnerships, trusts, and estates.
(c) Foreign partnerships.
(1) Determination of payee.
(i) Payments treated as made to partners.
(ii) Payments treated as made to the partnership.
(iii) Rules for reliably associating a payment with documentation.
(iv) Coordination with chapter 4 for payments made to foreign partnerships.
(v) Examples.
(2) Withholding foreign partnerships.
(i) Reliance on claim of withholding foreign partnership status.
(ii) Withholding agreement.
(iii) Withholding responsibility.
(iv) Withholding certificate from a withholding foreign partnership.
(3) Nonwithholding foreign partnerships.
(i) Reliance on claim of foreign partnership status.
(ii) Reliance on claim of reduced withholding by a partnership for its partners.
(iii) Withholding certificate from a nonwithholding foreign partnership.
(iv) Withholding statement provided by nonwithholding foreign partnership and coordination with chapter 4.
(v) Withholding and reporting by a foreign partnership.
(d) Presumption rules.
(1) In general.
(2) Determination of partnership status as U.S. or foreign in the absence of documentation.
(3) Determination of partners' status in the absence of certain documentation.
(4) Determination by a withholding foreign partnership of the status of its partners.
(e) Foreign trusts and estates.
(1) In general.
(2) Payments to foreign complex trusts and foreign estates.
(3) Payees of payments to foreign simple trusts and foreign grantor trusts.
(i) Payments for which beneficiaries and owners are payees.
(ii) Payments for which trust is payee.
(iii) Coordination with chapter 4 for payments made to foreign simple trusts and foreign grantor trusts.
(4) Reliance on claim of foreign complex trust or foreign estate status.
(5) Foreign simple trust and foreign grantor trust.
(i) Reliance on claim of foreign simple trust or foreign grantor trust status.
(ii) Reliance on claim of reduced withholding by a foreign simple trust or foreign grantor trust for its beneficiaries or owners.
(iii) Withholding certificate from foreign simple trust or foreign grantor trust.
(iv) Withholding statement provided by foreign simple trust or foreign grantor trust and coordination with chapter 4.
(v) Withholding foreign trusts.
(6) Presumption rules.
(i) In general.
(ii) Determination of status as U.S. or foreign trust or estate in the absence of documentation.
(iii) Determination of beneficiary or owner's status in the absence of certain documentation.
(f) Failure to receive withholding certificate timely or to act in accordance with applicable presumptions.
(g) Effective/applicability date.
(a) In general.
(b) Reliance on claim of reduced withholding under an income tax treaty.
(1) In general.
(i) Identification of limitation on benefits provisions.
(ii) Reason to know based on existence of treaty.
(2) Payment to fiscally transparent entity.
(i) In general.
(ii) Certification by qualified intermediary.
(iii) Dual treatment.
(iv) Examples.
(3) Certified TIN.
(4) Claim of benefits under an income tax treaty by a U.S. person.
(c) Exemption from requirement to furnish a taxpayer identifying number and special documentary evidence rules for certain income.
(1) General rule.
(2) Income to which special rules apply.
(3) Certificate of residence.
(4) Documentary evidence establishing residence in the treaty country.
(i) Individuals.
(ii) Persons other than individuals.
(5) Statements regarding entitlement to treaty benefits.
(i) Statement regarding conditions under a limitation on benefits provision.
(ii) Statement regarding whether the taxpayer derives the income.
(d) Joint owners.
(e) Competent authority.
(f) Failure to receive withholding certificate timely.
(g) Special taxpayer identifying number rule for certain foreign individuals claiming treaty benefits.
(1) General rule.
(2) Special rule.
(3) Requirement that an ITIN be requested during the first business day following payment.
(4) Definition of unexpected payment.
(5) Examples.
(h) Dividend equivalents.
(i) Effective/applicability dates.
(1) General rule.
(2) Dividend equivalents.
(a) Withholding agent defined.
(1) In general.
(2) Withholding agent with respect to dividend equivalents.
(3) Examples.
(4) Effective/applicability date.
(b) Standards of knowledge.
(1) In general.
(2) Reason to know.
(3) Financial institutions—limits on reason to know.
(i) In general.
(ii) Limits on reason to know for preexisting obligations.
(4) Rules applicable to withholding certificates.
(i) In general.
(ii) Examples.
(5) Withholding certificate—establishment of foreign status.
(i) Classification of U.S. status, U.S. address, or U.S. telephone number.
(ii) U.S. place of birth.
(iii) Standing instructions with respect to offshore obligations.
(6) Withholding certificate—claim of reduced rate of withholding under treaty.
(i) Permanent residence address.
(ii) Mailing address.
(iii) Standing instructions.
(7) Documentary evidence.
(8) Documentary evidence—establishment of foreign status.
(i) Documentary evidence received prior to January 1, 2001.
(ii) Documentary evidence received after December 31, 2000.
(A) Treatment of individual's foreign status.
(B) Presumption of entity's foreign status.
(iii) U.S. place of birth.
(iv) Standing instructions with respect of offshore obligations.
(9) Documentary evidence—claim of reduced rate of withholding under treaty.
(i) Permanent residence address and mailing address.
(ii) Standing instructions.
(10) Indirect account holders.
(11) Limits on reason to know for multiple obligations belonging to a single person.
(12) Reasonable explanation supporting claim of foreign status.
(13) Additional guidance.
(c) Agent.
(1) In general.
(2) Authorized agent.
(3) Liability of withholding agent acting through an agent.
(d) United States obligations.
(e) Assumed obligations.
(f) Conduit financing arrangements.
(1) Liability of withholding agent.
(2) Exception for withholding agents that do not know of conduit financing arrangement.
(i) In general.
(ii) Examples.
(g) Effective/applicability date.
(a) Foreign governments.
(b) Reliance on claim of exemption by foreign government.
(c) Income of a foreign central bank of issue or the Bank for International
Settlements.
(1) Certain interest income.
(2) Bankers' acceptances.
(d) Exemption for payments to international organizations.
(e) Failure to receive withholding certificate timely and other applicable procedures.
(f) Effective date.
(1) In general.
(2) Transition rules.
(a) Exemption from withholding for exempt income.
(b) Reliance on foreign organization's claim of exemption from withholding.
(1) General rule.
(2) Withholding certificate.
(3) Presumptions in the absence of documentation.
(4) Reason to know.
(c) Failure to receive withholding certificate timely and other applicable procedures.
(d) Effective date.
(1) In general.
(2) Transition rules.
(a) In general.
(b) Exception.
(c) Liability.
(d) Examples.
(e) Effective date.
Authorizing Statute
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Rules and regulations26 U.S.C. § 7805
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Advanced manufacturing production credit26 U.S.C. § 45X
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Alcohol, etc., used as fuel26 U.S.C. § 40
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Gross income defined26 U.S.C. § 61
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Transfers of excess pension assets to retiree health accounts26 U.S.C. § 420
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Partial exclusion for gain from certain small business stock26 U.S.C. § 1202
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Tax treatment of stripped bonds26 U.S.C. § 1286
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Current taxation of income from qualified electing funds26 U.S.C. § 1293
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Imposition of tax on certain foreign procurement26 U.S.C. § 5000C
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Returns regarding payments of interest26 U.S.C. § 6049
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Signing of returns and other documents26 U.S.C. § 6061
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General requirement of return, statement, or list26 U.S.C. § 6011
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Income from discharge of indebtedness26 U.S.C. § 108
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Indian general welfare benefits26 U.S.C. § 139E
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Bonds must be registered to be tax exempt; other requirements26 U.S.C. § 149
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Trade or business expenses26 U.S.C. § 162
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Accelerated cost recovery system26 U.S.C. § 168
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Amortizable bond premium26 U.S.C. § 171
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Golden parachute payments26 U.S.C. § 280G
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Distributions of stock and stock rights26 U.S.C. § 305
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Transfer to corporation controlled by transferor26 U.S.C. § 351
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Special rules for long-term contracts26 U.S.C. § 460
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Determination of basis of partner’s interest26 U.S.C. § 705
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Taxes of foreign countries and of possessions of United States26 U.S.C. § 901
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Controlled foreign corporations; United States persons26 U.S.C. § 957
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New energy efficient home credit26 U.S.C. § 45L
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2-percent floor on miscellaneous itemized deductions26 U.S.C. § 67
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Certain death benefits26 U.S.C. § 101
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Qualified business income26 U.S.C. § 199A
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Installment method26 U.S.C. § 453
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Certain payments for the use of property or services26 U.S.C. § 467
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Partners, not partnership, subject to tax26 U.S.C. § 701
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Extent of recognition of gain or loss on distribution26 U.S.C. § 731
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Capitalization of certain policy acquisition expenses26 U.S.C. § 848
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Special rules for determining source26 U.S.C. § 863
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Income of foreign governments and of international organizations26 U.S.C. § 892
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Definitions and special rules26 U.S.C. § 6241
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Computation and payment of tax26 U.S.C. § 1503
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Adjusted gross income defined26 U.S.C. § 62
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Treatment of loans with below-market interest rates26 U.S.C. § 7872
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Basis to distributees26 U.S.C. § 358
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Minimum participation standards26 U.S.C. § 410
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Other definitions and special rules26 U.S.C. § 860G
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Adjustments required by changes in method of accounting26 U.S.C. § 481
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Definitions26 U.S.C. § 7701
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Insurance income26 U.S.C. § 953
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Returns relating to actions affecting basis of specified securities26 U.S.C. § 6045B
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Information relating to certain trusts and annuity plans26 U.S.C. § 6047
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Enhanced oil recovery credit26 U.S.C. § 43
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Energy efficient commercial buildings deduction26 U.S.C. § 179D
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Redemption through use of related corporations26 U.S.C. § 304
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Certain stock purchases treated as asset acquisitions26 U.S.C. § 338
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Special limitations on certain excess credits, etc.26 U.S.C. § 383
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Optional treatment of elective deferrals as Roth contributions26 U.S.C. § 402A
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General rule for taxable year of inclusion26 U.S.C. § 451
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Qualified ABLE programs26 U.S.C. § 529A
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Charitable remainder trusts26 U.S.C. § 664
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Nonrecognition of gain or loss on contribution26 U.S.C. § 721
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Investment of earnings in United States property26 U.S.C. § 956
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Definitions and special rule26 U.S.C. § 1377
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Relief from joint and several liability on joint return26 U.S.C. § 6015
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Return of S corporation26 U.S.C. § 6037
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Notice of certain transfers to foreign persons26 U.S.C. § 6038B
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Information at source26 U.S.C. § 6041
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Imposition of accuracy-related penalty on underpayments26 U.S.C. § 6662
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Tax imposed26 U.S.C. § 1
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Railroad track maintenance credit26 U.S.C. § 45G
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Zero-emission nuclear power production credit26 U.S.C. § 45U
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Rehabilitation credit26 U.S.C. § 47
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Clean electricity investment credit26 U.S.C. § 48E
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Special rules26 U.S.C. § 52
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Election to expense certain depreciable business assets26 U.S.C. § 179
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Individual retirement accounts26 U.S.C. § 408
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Special rules for nondealers26 U.S.C. § 453A
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Deductions limited to amount at risk26 U.S.C. § 465
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Exemption from tax on corporations, certain trusts, etc.26 U.S.C. § 501
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Definition of regulated investment company26 U.S.C. § 851
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Source rules for personal property sales26 U.S.C. § 865
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Tax on nonresident alien individuals26 U.S.C. § 871
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Foreign base company income26 U.S.C. § 954
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S corporation defined26 U.S.C. § 1361
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Definitions26 U.S.C. § 1402
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Distributions of property26 U.S.C. § 301
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Life insurance contract defined26 U.S.C. § 7702
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Previously-owned clean vehicles26 U.S.C. § 25E
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Electricity produced from certain renewable resources, etc.26 U.S.C. § 45
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Clean fuel production credit26 U.S.C. § 45Z
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Taxation of employee annuities26 U.S.C. § 403
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Last-in, first-out inventories26 U.S.C. § 472
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Allocation of income and deductions among taxpayers26 U.S.C. § 482
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Definitions applicable to subparts A, B, C, and D26 U.S.C. § 643
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Taxable years of partner and partnership26 U.S.C. § 706
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Disposition of investment in United States real property26 U.S.C. § 897
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Administrative adjustment request by partnership26 U.S.C. § 6227
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Citizens or residents of the United States living abroad26 U.S.C. § 911
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Residence and source rules involving possessions26 U.S.C. § 937
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Rules relating to expatriated entities and their foreign parents26 U.S.C. § 7874
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Regulations26 U.S.C. § 1502
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Capitalization and inclusion in inventory costs of certain expenses26 U.S.C. § 263A
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Foreign corporations26 U.S.C. § 367
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Roth IRAs26 U.S.C. § 408A
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Minimum vesting standards26 U.S.C. § 411
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Partner’s distributive share26 U.S.C. § 704
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Unrealized receivables and inventory items26 U.S.C. § 751
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Taxation of residual interests26 U.S.C. § 860C
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Exclusions from gross income26 U.S.C. § 883
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Income affected by treaty26 U.S.C. § 894
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Other definitions and special rules26 U.S.C. § 989
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Special rules26 U.S.C. § 1474
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Returns of brokers26 U.S.C. § 6045
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Information returns of tax return preparers26 U.S.C. § 6060
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Authority to make credits or refunds26 U.S.C. § 6402
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Failure by individual to pay estimated income tax26 U.S.C. § 6654
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Interest on certain home mortgages26 U.S.C. § 25
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Credit for qualified commercial clean vehicles26 U.S.C. § 45W
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Interest on State and local bonds26 U.S.C. § 103
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Qualified lessee construction allowances for short-term leases26 U.S.C. § 110
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Losses26 U.S.C. § 165
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Charitable, etc., contributions and gifts26 U.S.C. § 170
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Incentive stock options26 U.S.C. § 422
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Deemed paid credit for subpart F inclusions26 U.S.C. § 960
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Election of mark to market for marketable stock26 U.S.C. § 1296
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Returns relating to certain life insurance contract transactions26 U.S.C. § 6050Y
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Clean vehicle credit26 U.S.C. § 30D
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Credit for carbon oxide sequestration26 U.S.C. § 45Q
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Amount of credit26 U.S.C. § 46
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Advanced manufacturing investment credit26 U.S.C. § 48D
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Arbitrage26 U.S.C. § 148
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Amortization of goodwill and certain other intangibles26 U.S.C. § 197
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Interest on education loans26 U.S.C. § 221
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Disallowance of certain entertainment, etc., expenses26 U.S.C. § 274
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Qualifications for tax credit employee stock ownership plans26 U.S.C. § 409
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Unrelated debt-financed income26 U.S.C. § 514
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Rules for allocation of basis26 U.S.C. § 755
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Rules for certain reserves26 U.S.C. § 807
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Special rules in case of foreign oil and gas income26 U.S.C. § 907
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Basis of property acquired from a decedent26 U.S.C. § 1014
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Special rules26 U.S.C. § 1298
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Definitions26 U.S.C. § 3401
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Extension of time for filing returns26 U.S.C. § 6081
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Renumbered § 45C]26 U.S.C. § 28
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Credit for production of clean hydrogen26 U.S.C. § 45V
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Energy credit26 U.S.C. § 48
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Limitation on credit26 U.S.C. § 904
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Qualified pension, profit-sharing, and stock bonus plans26 U.S.C. § 401
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Dependent care assistance programs26 U.S.C. § 129
-
Special rules for nuclear decommissioning costs26 U.S.C. § 468A
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Mark to market accounting method for dealers in securities26 U.S.C. § 475
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Basis of distributed property other than money26 U.S.C. § 732
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Straddles26 U.S.C. § 1092
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Qualified electing fund26 U.S.C. § 1295
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Averaging of farm income26 U.S.C. § 1301
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Withholdable payments to foreign financial institutions26 U.S.C. § 1471
-
Definitions26 U.S.C. § 1504
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Basis information to persons acquiring property from decedent26 U.S.C. § 6035
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Information with respect to certain foreign-owned corporations26 U.S.C. § 6038A
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Returns relating to cash received in trade or business, etc.26 U.S.C. § 6050I
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Credit for increasing research activities26 U.S.C. § 41
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Definitions and special rules26 U.S.C. § 150
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Passive activity losses and credits limited26 U.S.C. § 469
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Certain expenses for which credits are allowable26 U.S.C. § 280C
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Assumption of liability26 U.S.C. § 357
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Complete liquidations of subsidiaries26 U.S.C. § 332
-
Distribution of stock and securities of a controlled corporation26 U.S.C. § 355
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Period for computation of taxable income26 U.S.C. § 441
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General rule for taxable year of deduction26 U.S.C. § 461
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Special rules for modified guaranteed contracts26 U.S.C. § 817A
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Treatment of variable contracts26 U.S.C. § 817
-
Certain reinsurance agreements26 U.S.C. § 845
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Failure to file notice of redetermination of foreign tax26 U.S.C. § 6689
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Branch transactions26 U.S.C. § 987
-
Qualified zone property defined26 U.S.C. § 1397D
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Withholdable payments to other foreign entities26 U.S.C. § 1472
-
Liquidating, etc., transactions26 U.S.C. § 6043
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Verification of returns26 U.S.C. § 6065
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Mode or time of collection26 U.S.C. § 6302
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Transfer of certain credits26 U.S.C. § 6418
-
American Opportunity and Lifetime Learning credits26 U.S.C. § 25A
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Refundable credit for coverage under a qualified health plan26 U.S.C. § 36B
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Clean electricity production credit26 U.S.C. § 45Y
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Other special rules26 U.S.C. § 50
-
Treatment of community income26 U.S.C. § 66
-
Basis to corporations26 U.S.C. § 362
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Election of taxable year other than required taxable year26 U.S.C. § 444
-
Transactions between partner and partnership26 U.S.C. § 707
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Special allocation rules for certain asset acquisitions26 U.S.C. § 1060
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Discounted unpaid losses defined26 U.S.C. § 846
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Definitions and special rules26 U.S.C. § 864
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Capital asset defined26 U.S.C. § 1221
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Interest on tax deferral26 U.S.C. § 1291
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Passive foreign investment company26 U.S.C. § 1297
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Withholding of tax on nonresident aliens26 U.S.C. § 1441
-
Returns as to interests in foreign partnerships26 U.S.C. § 6046A
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State and local income tax refunds26 U.S.C. § 6050E
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Returns relating to exchanges of certain partnership interests26 U.S.C. § 6050K
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Returns relating to higher education tuition and related expenses26 U.S.C. § 6050S
-
Reporting of health insurance coverage26 U.S.C. § 6055
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Low-income housing credit26 U.S.C. § 42
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New markets tax credit26 U.S.C. § 45D
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Definitions and special rules26 U.S.C. § 414
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Qualified asset account; limitation on additions to account26 U.S.C. § 419A
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General rule for methods of accounting26 U.S.C. § 446
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Interest on certain deferred payments26 U.S.C. § 483
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Reserves for losses on loans of banks26 U.S.C. § 585
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Certain revocable trusts treated as part of estate26 U.S.C. § 645
-
Insurance company taxable income26 U.S.C. § 832
-
Income from sources within the United States26 U.S.C. § 861
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Treatment of certain foreign currency transactions26 U.S.C. § 988
-
Functional currency26 U.S.C. § 985
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Other definitions and special rules26 U.S.C. § 1275
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Election to extend time for payment of tax on undistributed earnings26 U.S.C. § 1294
-
Requirement to maintain minimum essential coverage26 U.S.C. § 5000A
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Returns by exempt organizations26 U.S.C. § 6033
-
Information with respect to foreign financial assets26 U.S.C. § 6038D
-
Returns relating to the cancellation of indebtedness by certain entities26 U.S.C. § 6050P
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Identifying numbers26 U.S.C. § 6109
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Elective payment of applicable credits26 U.S.C. § 6417
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Certain fringe benefits26 U.S.C. § 132
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Dependent defined26 U.S.C. § 152
-
Interest26 U.S.C. § 163
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Bad debts26 U.S.C. § 166
-
Special rules for credits and deductions26 U.S.C. § 642
-
General rule for inventories26 U.S.C. § 471
-
Political organizations26 U.S.C. § 527
-
Special rules applicable to sections 661 and 66226 U.S.C. § 663
-
Allowance of deductions and credits26 U.S.C. § 874
-
Branch profits tax26 U.S.C. § 884
-
Tax imposed on certain built-in gains26 U.S.C. § 1374
-
Foreign tax-exempt organizations26 U.S.C. § 1443
-
Valuation tables26 U.S.C. § 7520
-
Losses on small business stock26 U.S.C. § 1244
-
Distributions26 U.S.C. § 1368
-
Definitions26 U.S.C. § 1473
-
Information with respect to certain fines, penalties, and other amounts26 U.S.C. § 6050X
-
Failure by corporation to pay estimated income tax26 U.S.C. § 6655