§1.952-1. Subpart F income defined.
26 C.F.R. § 1.952-1
In general. For purposes of sections 951 through 964, a controlled foreign corporation's subpart F income for any taxable year shall, except as provided in paragraph (b) of this section and subject to the limitations of paragraphs (c) and (d) of this section, consist of the sum of—
The income derived by such corporation for such year from the insurance of United States risks (determined in accordance with the provisions of section 953 and §§ 1.953-1 through 1.953-6),
The income derived by such corporation for such year which constitutes foreign base company income (determined in accordance with the provisions of section 954 and §§ 1.954-1 through 1.954-8),
An amount equal to the product of—
The income of such corporation other than income which— (1) Is attributable to earnings and profits of the foreign corporation included in the gross income of a United States person under section 951 (other than by reason of this paragraph) (determined in accordance with the provisions of section 951 and § 1.951-1), or
(2) Is described in section 952(b),
The international boycott factor determined in accordance with the provisions of section 999(c)(1), or
In lieu of the amount determined under paragraph (a)(3)(i) of this section, the amount described under section 999(c)(2) of such international boycott income, and
The sum of the amount of any illegal bribes, kickbacks, or other payments paid after November 3, 1976, by or on behalf of the corporation during the taxable year of the corporation directly or indirectly to an official, employee, or agent in fact of a government. An amount is paid by a controlled foreign corporation where it is paid by an officer, director, employee, shareholder or agent of such corporation for the benefit of such corporation. For purposes of this section, the principles of section 162(c) and the regulations thereunder shall apply. In the case of payments made after September 3, 1982, a payment is illegal if the payment would be unlawful under the Foreign Corrupt Practices Act of 1977 if the payor were a United States person. The fair market value of an illegal payment made in the form of property or services shall be considered the amount of such illegal payment.
Exclusion of U.S. income—
Taxable years beginning before January 1, 1967. For rules applicable to taxable years beginning before January 1, 1967, see 26 CFR 1.952-1(b)(1) (Revisedof April 1, 1975).
Taxable years beginning after December 31, 1966. Notwithstanding paragraph (a) of this section, a controlled foreign corporation's subpart F income for any taxable year beginning after December 31, 1966, shall not include any item of income from sources within the United States which is effectively connected for that year with the conduct by such corporation of a trade or business in the United States unless, pursuant to a treaty to which the United States is a party, such item of income either is exempt from the income tax imposed by chapter 1 (relating to normal taxes and surtaxes) of the Code or is subject to such tax at a reduced rate.
Rule applicable under section 956 (b)(2). For purposes only of paragraph (b)(1))(viii) of § 1.956-2, an item of income derived by a controlled foreign corporation from sources within the United States with respect to which for the taxable year a tax is imposed in accordance with section 882(a) shall be considered described in section 952(b) whether or not such item of income would have constituted subpart F income for such year.
Limitation on a controlled foreign corporation's subpart F income—
In general. A United States shareholder's pro rata share (determined in accordance with the rules of paragraph (e) of § 1.951-1) of a controlled foreign corporation's subpart F income for any taxable year shall not exceed his pro rata share of the earnings and profits (as defined in section 964(a) and § 1.964-1) of such corporation for such taxable year, computed as of the close of such taxable year without diminution by reason of any distributions made during such taxable year, minus the sum of—
The amount, if any, by which such shareholder's pro rata share of— (a) The sum of such corporation's deficits in earnings and profits for prior taxable years beginning after December 31, 1962, plus
(b) The sum of such corporation's deficits in earnings and profits for taxable years beginning after December 31, 1959, and before January 1, 1963 (reduced by the sum of the earnings and profits (as so defined) of such corporation for any of such taxable years) exceeds
(c) The sum of such corporation's earnings and profits for prior taxable years beginning after December 31, 1962, which, with respect to such shareholder, are allocated to other earnings and profits under section 959(c)(3) and § 1.959-3; and
Such shareholder's pro rata share of any deficits in earnings and profits of other foreign corporations for a taxable year beginning after December 31, 1962, which are attributable to stock of such other foreign corporations owned by such shareholder within the meaning of section 958(a) and which, in accordance with section 952(d) and paragraph (d) of this section, are taken into account as a reduction in the controlled foreign corporation's earnings and profits for such taxable year.
Special rules. For purposes only of determining the limitation under subparagraph (1) of this paragraph on a United States shareholder's pro rata share of a controlled foreign corporation's subpart F income for any taxable year—
Status of foreign corporation. The earnings and profits, or deficit in earnings and profits, of a foreign corporation for any taxable year shall be taken into account whether or not such foreign corporation is a controlled foreign corporation at the time such earnings and profits are derived or such deficit in earnings and profits is incurred.
Deficits in earnings and profits taken into account only once. A controlled foreign corporation's deficit in earnings and profits for any taxable year preceding the taxable year shall be taken into account for the taxable year only to the extent such deficit has not been taken into account under this paragraph, paragraph (d) of this section, or paragraph (d)(2)(ii) of § 1.963-2 (applied as if section 963 had not been repealed by the Tax Reduction Act of 1975) in computing a minimum distribution, for any taxable year preceding the taxable year, to reduce earnings and profits of such preceding year of such controlled foreign corporation or of any other controlled foreign corporation. To the extent a controlled foreign corporation's (the “first corporation”) excess foreign base company shipping deductions for any taxable year (determined under § 1.955A-3(c)(2)(i)) reduce the foreign base company shipping income of another member of a related group (as defined in § 1.955A-2(b)), such deductions shall not be taken into account in determining the earnings and profits or deficits in earnings and profits of such first corporation for such taxable year for purposes of this paragraph (c) and paragraph (d) of this section. The rule of the preceding sentence shall not apply to the extent the excess foreign base company shipping deductions of the first corporation reduce the foreign base company shipping income of another member of a related group below zero.
Determination of pro rata share. A United States shareholder's pro rata share of a controlled foreign corporation's earnings and profits, or deficit in earnings and profits, for any taxable year shall be determined in accordance with the principles of paragraph (e) of § 1.951-1 and paragraph (d)(2)(ii) of § 1.963-2.
Illustrations. The application of this paragraph may be illustrated by the following examples:
Treatment of deficits in earnings and profits attributable to stock of other foreign corporation indirectly owned by a United States shareholder—
A United States shareholder owns (within the meaning of section 958(a)) stock in two or more foreign corporations in a chain of foreign corporations (as defined in subparagraph (2)(ii) of this paragraph), and
Any of the corporations in such chain has a deficit in earnings and profits for a taxable year beginning after December 31, 1962,
Special rules. For purposes of this paragraph—
Applicable rules. The special rules set forth in paragraph (c)(2) of this section shall apply.
“Chain” defined. A chain of foreign corporations shall, with respect to a United States shareholder, include—
(a) Any foreign corporation in which such shareholder owns (within the meaning of section 958(a)(1)(A)) stock but, only to the extent of the stock so owned and
(b) All foreign corporations in which such shareholder owns (within the meaning of section 958(a)(2)) stock, but only to the extent of the stock so owned by reason of his ownership of the stock referred to in (a) of this subdivision.
Allocation of deficit. If one or more foreign corporations (whether or not a controlled foreign corporation) includible in a chain of foreign corporations has a deficit in earnings and profits (determined under section 964(a) and § 1.964-1) for the taxable year, the amount of deficit taken into account under section 952(d) with respect to a United States shareholder in such chain as a reduction in earnings and profits for the taxable year of a controlled foreign corporation includible in such chain shall be an amount which bears the same ratio to such shareholder's pro rata share of the total deficit in earnings and profits for the taxable year of all includible foreign corporations as his pro rata share of the earnings and profits (determined under paragraph (c) of this section but without regard to the provisions of subparagraph (1)(ii) of such paragraph) for the taxable year of such includible controlled foreign corporation bears to his pro rata share of the total earnings and profits (as so determined under paragraph (c) of this section) for the taxable year of all includible controlled foreign corporations. The amount of deficit taken into account under this subdivision with respect to any controlled foreign corporation includible in a chain of foreign corporations shall not exceed the United States shareholder's pro rata share of the controlled foreign corporation's earnings and profits for the taxable year.
Taxable year. The taxable year from which a deficit is allocated under this paragraph, and the taxable year to which such deficit is allocated to reduce earnings and profits, shall be the taxable year of the foreign corporation ending with or within the taxable year of the United States shareholder described in subparagraph (1)(i) of this paragraph.
Illustration. The application of this paragraph may be illustrated by the following examples:
Application of current earnings and profits limitation—
In general. If the subpart F income (as defined in section 952(a)) of a controlled foreign corporation exceeds the foreign corporation's earnings and profits for the taxable year, the subpart F income includible in the income of the corporation's United States shareholders is reduced under section 952(c)(1)(A) in accordance with the following rules. The excess of subpart F income over current year earnings and profits shall—
First, proportionately reduce subpart F income in each separate category of the controlled foreign corporation, as defined in § 1.904-5(a)(4)(v), in which current earnings and profits are zero or less than zero;
Second, proportionately reduce subpart F income in each separate category in which subpart F income exceeds current earnings and profits; and
Third, proportionately reduce subpart F income in other separate categories.
Allocation to a category of subpart F income. An excess amount that is allocated under paragraph (e)(1) of this section to a separate category must be further allocated to a category of subpart F income if the separate category contains more than one category of subpart F income described in section 952(a) or, in the case of foreign base company income, described in § 1.954-1(c)(1)(iii)(A) (1) or (2). In such case, the excess amount that is allocated to the separate category must be allocated to the various categories of subpart F income within that separate category on a proportionate basis.
Recapture of subpart F income reduced by operation of earnings and profits limitation. Any amount in a category of subpart F income described in section 952(a) or, in the case of foreign base company income, described in § 1.954-1(c)(1)(iii)(A) (1) or (2) that is reduced by operation of the current year earnings and profits limitation of section 952(c)(1)(A) and this paragraph (e) shall be subject to recapture in a subsequent year under the rules of section 952(c)(2) and paragraph (f) of this section.
Coordination with sections 953 and 954. The rules of this paragraph (e) shall be applied after the application of sections 953 and 954 and the regulations under those sections, except as provided in § 1.954-1(d)(4)(ii).
Earnings and deficits retain separate limitation character. The income reduction rules of paragraph (e)(1) of this section shall apply only for purposes of determining the amount of an inclusion under section 951(a)(1)(A) from each separate category as defined in § 1.904-5(a)(4)(v) and the separate categories in which recapture accounts are established under section 952(c)(2) and paragraph (f) of this section. For rules applicable in computing post-1986 undistributed earnings, see generally section 902 and the regulations under that section. For rules relating to the allocation of deficits for purposes of computing foreign taxes deemed paid under section 960 with respect to an inclusion under section 951(a)(1)(A), see § 1.960-1(i).
Recapture of subpart F income in subsequent taxable year—
In general. If a controlled foreign corporation's subpart F income for a taxable year is reduced under the current year earnings and profits limitation of section 952(c)(1)(A) and paragraph (e) of this section, recapture accounts will be established and subject to recharacterization in any subsequent taxable year to the extent the recapture accounts were not previously recharacterized or distributed, as provided in paragraphs (f)(2) and (3) of this section.
Rules of recapture—
Recapture account. If a category of subpart F income described in section 952(a) or, in the case of foreign base company income, described in § 1.954-1(c)(1)(iii)(A) (1) or (2) is reduced under the current year earnings and profits limitation of section 952(c)(1)(A) and paragraph (e) of this section for a taxable year, the amount of such reduction shall constitute a recapture account.
Recapture. Each recapture account of the controlled foreign corporation will be recharacterized, on a proportionate basis, as subpart F income in the same separate category (as defined in § 1.904-5(a)(4)(v)) as the recapture account to the extent that current year earnings and profits exceed subpart F income in a taxable year. The United States shareholder must include his pro rata share (determined under the rules of § 1.951-1(e)) of each recharacterized amount in income as subpart F income in such separate category for the taxable year.
Reduction of recapture account and corresponding earnings. Each recapture account, and post-1986 undistributed earnings in the separate category containing the recapture account, will be reduced in any taxable year by the amount which is recharacterized under paragraph (f)(2)(ii) of this section. In addition, each recapture account, and post-1986 undistributed earnings in the separate category containing the recapture account, will be reduced in the amount of any distribution out of that account (as determined under the ordering rules of section 959(c) and paragraph (f)(3)(ii) of this section).
Distribution ordering rules—
Coordination of recapture and distribution rules. If a controlled foreign corporation distributes an amount out of earnings and profits described in section 959(c)(3) in a year in which current year earnings and profits exceed subpart F income and there is an amount in a recapture account for such year, the recapture rules will apply first.
Distributions reduce recapture accounts first. Any distribution made by a controlled foreign corporation out of earnings and profits described in section 959(c)(3) shall be treated as made first on a proportionate basis out of the recapture accounts in each separate category to the extent thereof (even if the amount in the recapture account exceeds post-1986 undistributed earnings in the separate category containing the recapture account). Any remaining distribution shall be treated as made on a proportionate basis out of the remaining earnings and profits of the controlled foreign corporation in each separate category. See section 904(d)(3)(D).
Examples. The application of paragraphs (e) and (f) of this section may be illustrated by the following examples:
Effective date. Paragraph (e) of this section and this paragraph (f) apply to taxable years of a controlled foreign corporation beginning after March 3, 1997.
Treatment of distributive share of partnership income—
In general. A controlled foreign corporation's distributive share of any item of income of a partnership is income that falls within a category of subpart F income described in section 952(a) to the extent the item of income would have been income in such category if received by the controlled foreign corporation directly. For specific rules regarding the treatment of a distributive share of partnership income under certain provisions of subpart F, see §§ 1.954-1(g), 1.954-2(a)(5), 1.954-3(a)(6), and 1.954-4(b)(2)(iii).
Example. The application of this paragraph (g) may be illustrated by the following example:
Effective date. This paragraph (g) applies to taxable years of a controlled foreign corporation beginning on or after July 23, 2002.
Notes, amendments, and revision history
Amendments
[T.D. 6795, 30 FR 938, Jan. 29, 1965]
Authority
Authority: 26 U.S.C. 7805, unless otherwise noted. Section 1.1(h)-1 also issued under 26 U.S.C. 1(h); Section 1.21-1 also issued under 26 U.S.C. 21(f); Section 1.21-2 also issued under 26 U.S.C. 21(f); Section 1.21-3 also issued under 26 U.S.C. 21(f); Section 1.21-4 also issued under 26 U.S.C. 21(f); Section 1.25-1T also issued under 26 U.S.C. 25; Section 1.25-2T also issued under 26 U.S.C. 25; Section 1.25-3 also issued under 26 U.S.C. 25; Section 1.25-3T also issued under 26 U.S.C. 25; Section 1.25-4T also issued under 26 U.S.C. 25; Section 1.25-5T also issued under 26 U.S.C. 25; Section 1.25-6T also issued under 26 U.S.C. 25; Section 1.25-7T also issued under 26 U.S.C. 25; Section 1.25-8T also issued under 26 U.S.C. 25; Section 1.25A-1 also issued under section 26 U.S.C. 25A(i); Section 1.25A-2 also issued under section 26 U.S.C. 25A(i); Section 1.25A-3 also issued under section 26 U.S.C. 25A(i); Section 1.25A-4 also issued under section 26 U.S.C. 25A(i); Section 1.25A-5 also issued under section 26 U.S.C. 25A(i); Section 1.25E-1 also issued under 26 U.S.C. 25E. Section 1.25E-2 also issued under 26 U.S.C. 25E. Section 1.25E-3 also issued under 26 U.S.C. 25E, 26 U.S.C. 30D(g)(1) and (g)(10), and 26 U.S.C. 6011. Section 1.28-0 also issued under 26 U.S.C. 28(d)(5); Section 1.28-1 also issued under 26 U.S.C. 28(d)(5); Section 1.30-1 also issued under 26 U.S.C. 30(d)(2); Section 1.30C-3 also issued under 26 U.S.C. 30; Section 1.30D-1 also issued under 26 U.S.C. 30D. Section 1.30D-2 also issued under 26 U.S.C. 30D. Section 1.30D-3 also issued under 26 U.S.C. 30D. Section 1.30D-4 also issued under 26 U.S.C. 30D and 26 U.S.C. 45W(d)(3). Section 1.30D-5 also issued under 26 U.S.C. 30D and 26 U.S.C. 6011. Section 1.30D-6 also issued under 26 U.S.C. 30D. Section 1.36B-1 also issued under 26 U.S.C. 36B(h). Section 1.36B-2 also issued under 26 U.S.C. 36B(h). Section 1.36B-3 also issued under 26 U.S.C. 36B(h). Section 1.36B-4 also issued under 26 U.S.C. 36B(h). Section 1.36B-5 also issued under 26 U.S.C. 36B(h). Section 1.36B-6 also issued under 26 U.S.C. 36B(h). Section 1.41-4 also issued under 26 U.S.C. 41(d)(4)(E). Section 1.41-6 also issued under 26 U.S.C. 41(f)(1) and 1502; Section 1.41-8 also issued under 26 U.S.C. 41(c)(4)(B); Section 1.41-8T also issued under 26 U.S.C. 41(c)(4)(B); Section 1.41-9 also issued under 26 U.S.C. 41(c)(5)(C); Section 1.41-9T also issued under 26 U.S.C. 41(c)(5)(C); Section 1.42-1 also issued under 26 U.S.C. 42(n); Section 1.42-1T also issued under 26 U.S.C. 42(n); Section 1.42-3 also issued under 26 U.S.C. 42(n); Section 1.42-4 also issued under 26 U.S.C. 42(n); Section 1.42-5 also issued under 26 U.S.C. 42(n); Sections 1.42-6, 1.42-8, 1.42-9, 1.42-10, 1.42-11, and 1.42-12, also issued under 26 U.S.C. 42(n); Section 1.42-13 also issued under 26 U.S.C. 42(n); Section 1.42-14 also issued under 26 U.S.C. 42(n); Section 1.42-15 also issued under 26 U.S.C. 42(n); Section 1.42-16 also issued under 26 U.S.C. 42(n); Section 1.42-17 also issued under 26 U.S.C. 42(n); Section 1.42-18 also issued under 26 U.S.C. 42(h)(6)(F) and 42(h)(6)(K); Section 1.42-19 also issued under 26 U.S.C. 42(n); Sections 1.43-0—1.43-7 also issued under section 26 U.S.C. 43; Section 1.45-6 also issued under 26 U.S.C. 45. Section 1.45-7 also issued under 26 U.S.C. 45. Section 1.45-8 also issued under 26 U.S.C. 45. Section 1.45-12 also issued under 26 U.S.C. 45. Section 1.45D-1 also issued under 26 U.S.C. 45D(e)(2) and (i); Section 1.45G-1 also issued under 26 U.S.C. 45G(e)(2); Section 1.45L-3 also issued under 26 U.S.C. 45L. Sections 1.45Q-1, 1.45Q-2, 1.45Q-3, 1.45Q-4, and 1.45Q-5 also issued under 26 U.S.C. 45Q(h). Section 1.45Q-3 also issued under 26 U.S.C. 45Q(f)(2). Section 1.45Q-4 also issued under 26 U.S.C. 45Q(f)(5). Section 1.45Q-5 also issued under 26 U.S.C. 45Q(f)(4). Section 1.45Q-6 also issued under 26 U.S.C. 45Q. Section 1.45U-3 also issued under 26 U.S.C. 45U. Section 1.45V-1 also issued under 26 U.S.C. 45V(c)(1)(B) and 45V(f). Section 1.45V-2 also issued under 26 U.S.C. 45V(c)(1)(B) and 45V(f). Section 1.45V-3 also issued under 26 U.S.C. 45V. Section 1.45V-4 also issued under 26 U.S.C. 45V(c)(1)(B) and 45V(f). Section 1.45V-5 also issued under 26 U.S.C. 45V(c)(1)(B) and 45V(f). Section 1.45V-6 also issued under 26 U.S.C. 45V(c)(1)(B) and 45V(f). Section 1.45X-1 also issued under 26 U.S.C. 45X, 6001, 6417(h) and 6418(h). Section 1.45X-2 also issued under 26 U.S.C. 45X and 1502. Section 1.45X-3 also issued under 26 U.S.C. 6001. Section 1.45X-4 also issued under 26 U.S.C. 6001. Section 1.45Y-1 also issued under 26 U.S.C. 45Y(f). Section 1.45Y-2 also issued under 26 U.S.C. 45Y(f). Section 1.45Y-3 also issued under 26 U.S.C. 45Y(f). Section 1.45Y-4 also issued under 26 U.S.C. 45Y(f). Section 1.45Y-5 also issued under 26 U.S.C. 45Y(b) and (f). Section 1.45Z-3 also issued under 26 U.S.C. 45Z. Section 1.46-5 also issued under 26 U.S.C. 46(d)(6) and 26 U.S.C. 47(a)(3)(C); Section 1.46-6 also issued under 26 U.S.C. 46(f)(7); Section 1.47-1 also issued under 26 U.S.C. 47(a); Section 1.48-9 also issued under 26 U.S.C. 48(a)(3)(D)(i) and (16). Section 1.48-13 also issued under 26 U.S.C. 48(a)(10)(C) and (16). Section 1.48-14 also issued under 26 U.S.C. 48(a)(16). Section 1.48-15 also issued under 26 U.S.C. 48(a)(15) Section 1.48D-6 also issued under 26 U.S.C. 48D(d)(6); Section 1.48D-6T also issued under 26 U.S.C. 48D(d)(2)(E) and (6); Section 1.48(e)-1 issued under 26 U.S.C. 48. Section 1.48E-1 also issued under 26 U.S.C. 48E(i). Section 1.48E-2 also issued under 26 U.S.C. 48E(i). Section 1.48E-3 also issued under 26 U.S.C. 48E(i). Section 1.48E-4 also issued under 26 U.S.C. 48E(i). Section 1.48E-5 also issued under 26 U.S.C. 48E(i). Section 1.48E(h)-1 also issued under 26 U.S.C. 48E(i). Section 1.50-2 also issued under 26 U.S.C. 50(a)(3)(C), and 50(a)(6). Sections 1.50A—1.50B also issued under 85 Stat. 553 (26 U.S.C. 40(b)); Section 1.52-1 also issued under 26 U.S.C. 52(b); Section 1.56(g)-1 also issued under section 7611(g)(3) of the Omnibus Budget Reconciliation Act of 1989 (Pub. L. 101-239, 103 Stat. 2373). Section 1.59A-0 also issued under 26 U.S.C. 59A(i). Section 1.59A-1 also issued under 26 U.S.C. 59A(i). Section 1.59A-2 also issued under 26 U.S.C. 59A(i). Section 1.59A-3 also issued under 26 U.S.C. 59A(i). Section 1.59A-4 also issued under 26 U.S.C. 59A(i). Section 1.59A-5 also issued under 26 U.S.C. 59A(i). Section 1.59A-6 also issued under 26 U.S.C. 59A(i). Section 1.59A-7 also issued under 26 U.S.C. 59A(i). Section 1.59A-8 also issued under 26 U.S.C. 59A(i). Section 1.59A-9 also issued under 26 U.S.C. 59A(i). Section 1.59A-10 also issued under 26 U.S.C. 59A(i). Section 1.61-2T also issued under 26 U.S.C. 61. Section 1.61-21 also issued under 26 U.S.C. 61. Sections 1.62-1T and 1.62-2 also issued under 26 U.S.C. 62. Section 1.66-4 also issued under 26 U.S.C. 66(c); Sections 1.67-2T and 1.67-3T also issued under 26 U.S.C. 67(c). Section 1.67-3 also issued under 26 U.S.C. 67(c). Section 1.67-4 also issued under 26 U.S.C. 67(e). Sections 1.72-4, 1.72-5, 1.72-6, 1.72-7, 1.72-8, and 1.72-11 also issued under 26 U.S.C. 72(c). Section 1.78-1 also issued under 26 U.S.C. 245A(g). Section 1.101-7 also issued under 26 U.S.C. 101(d)(2)(B)(ii). Section 1.103-10 also issued under 26 U.S.C. 103(b)(6). Section 1.103A-2 also issued under 26 U.S.C. 103A(j). Section 1.108-1 also issued under 26 U.S.C. 108(e)(8) and 108(e)(10(B). Section 1.108-2 also issued under 26 U.S.C. 108. Section 1.108-3 also issued under 26 U.S.C. 108, 267, and 1502. Section 1.108-4 also issued under 26 U.S.C. 108. Section 1.108-5 also issued under 26 U.S.C. 108. Section 1.108(c)-1 also issued under the authority of 26 U.S.C. 108(d)(9). Section 1.108(i)-0 also issued under 26 U.S.C. 108(i)(7) and 1502. Section 1.108(i)-1 also issued under 26 U.S.C. 108(i)(7) and 1502. Section 1.108(i)-2 also issued under 26 U.S.C. 108(i)(7). Section 1.108(i)-3 also issued under 26 U.S.C. 108(i)(7) and 1502. Section 1.110-1 also issued under 26 U.S.C. 110(d). Sections 1.132-0 through 1.132-8T also issued under 26 U.S.C. 132(o). Section 1.139E-1 also issued under 26 U.S.C. 139E. Section 1.139E-1(d)(6) also issued under 26 U.S.C. 7872. Section 1.139E-2 also issued under 26 U.S.C. 139E. Section 1.148-0 through 1.148-11 also issued under 26 U.S.C. 148(i). Section 1.148-6 also issued under 26 U.S.C. 148 (f), (g), and (i). Section 1.149(b)-1 also issued under 26 U.S.C. 149(b)(3)(B) (v). Section 1.149(d)-1 also issued under 26 U.S.C. 149(d)(7). Section 1.149(e)-1 also issued under 26 U.S.C. 149(e). Section 1.149(g)-1 also issued under 26 U.S.C. 149(g)(5). Section 1.150-4 also issued under 26 U.S.C. 150 (c)(5). Section 1.152-4 also issued under 26 U.S.C. 152(e). Section 1.162-24 also issued under 26 U.S.C. 162(h). Section 1.162(k)-1 is also issued under section 26 U.S.C. 162(k). Section 1.163-8T also issued under 26 U.S.C. 469(k)(4). Section 1.163-9T also issued under 26 U.S.C. 163(h)(3)(D). Section 1.163(j)-1 also issued under 26 U.S.C. 163(j)(8)(B) and 26 U.S.C. 1502. Section 1.163(j)-2 also issued under 26 U.S.C. 1502. Section 1.163(j)-3 also issued under 26 U.S.C. 1502. Section 1.163(j)-4 also issued under 26 U.S.C. 163(j)(8)(B) and 26 U.S.C. 1502. Section 1.163(j)-5 also issued under 26 U.S.C. 1502. Section 1.163(j)-6 also issued under 26 U.S.C. 163(j)(8)(B) and 26 U.S.C. 1502. Section 1.163(j)-7 also issued under 26 U.S.C. 163(j)(8)(B) and 26 U.S.C. 1502. Section 1.163(j)-8 also issued under 26 U.S.C. 163(j)(8)(B). Section 1.163(j)-9 also issued under 26 U.S.C. 163(j)(7)(B) and (C) and 26 U.S.C. 1502. Section 1.163(j)-10 also issued under 26 U.S.C. 163(j)(8)(B) and 26 U.S.C. 1502. Section 1.163(j)-11 also issued under 26 U.S.C. 1502. Section 1.165-12 also issued under 26 U.S.C. 165(j)(3). Section 1.166-10 also issued under 26 U.S.C. 166(f). Section 1.168(d)-1 also issued under 26 U.S.C. 168(d)(3). Section 1.168(f)(8)-1T also added under sec. 112(c), Black Lung Benefits Revenue Act of 1981 (Pub. L. 97-119). Section 1.168(h)-1 also issued under 26 U.S.C. 168. Section 1.168(i)-1 also issued under 26 U.S.C. 168(i)(4). Section 1.168(i)-1T also issued under 26 U.S.C. 168(i)(4). Section 1.168(i)-2 also issued under 26 U.S.C. 168. Section 1.168(i)-4 also issued under 26 U.S.C. 168(i)(5). Section 1.168(j)-1T also added under 26 U.S.C. 168(j)(10). Section 1.170A-1 also issued under 26 U.S.C. 170(a). Section 1.170A-6 also issued under 26 U.S.C. 170(f)(4); 26 U.S.C. 642(c)(5). Section 1.170A-12 also issued under 26 U.S.C. 170(f)(4). Section 1.170A-13 also issued under 26 U.S.C. 170(f)(8). Section 1.170A-14 also issued under 26 U.S.C. 170(f)(11) and 170(h)(7). Section 1.170A-15 also issued under 26 U.S.C. 170(a)(1). Section 1.170A-16 also issued under 26 U.S.C. 170(f)(11), 170(f)(19), 170(h)(7)(G), 6001, and 6011. Section 1.170A-17 also issued under 26 U.S.C. 170(a)(1) and 170(f)(11). Section 1.170A-18 also issued under 26 U.S.C. 170(a)(1). Section 1.171-2 also issued under 26 U.S.C. 171(e). Section 1.171-3 also issued under 26 U.S.C. 171(e). Section 1.171-4 also issued under 26 U.S.C. 171(c). Section 1.179-1 also issued under 26 U.S.C. 179(d)(6) and (10). Section 1.179-4 also issued under 26 U.S.C. 179(c). Section 1.179-6 also issued under 26 U.S.C. 179(c). Section 1.179D-3 also issued under 26 U.S.C. 179D. Section 1.197-2 also issued under 26 U.S.C. 197. Section 1.199A-1 also issued under 26 U.S.C. 199A(f)(4). Section 1.199A-2 also issued under 26 U.S.C. 199A(b)(5), (f)(1)(A), (f)(4), and (h). Section 1.199A-3 also issued under 26 U.S.C. 199A(c)(4)(C) and (f)(4). Section 1.199A-4 also issued under 26 U.S.C. 199A(f)(4). Section 1.199A-5 also issued under 26 U.S.C. 199A(f)(4). Section 1.199A-6 also issued under 26 U.S.C. 199A(f)(1)(B) and (f)(4). Section 1.199A-7 also issued under 26 U.S.C. 199A(f)(4) and (g)(6). Section 1.199A-8 also issued under 26 U.S.C. 199A(g)(6). Section 1.199A-9 also issued under 26 U.S.C. 199A(g)(6). Section 1.199A-10 also issued under 26 U.S.C. 199A(g)(6). Section 1.199A-11 also issued under 26 U.S.C. 199A(g)(6). Section 1.199A-12 also issued under 26 U.S.C. 199A(g)(6). Section 1.216-2 also issued under 26 U.S.C. 216(d). Section 1.221-2 also issued under 26 U.S.C. 221(d). Section 1.224-1 also issued under 26 U.S.C. 224(d)(2)(C) and (g) and sec. 70201(h) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act. Section 1.245A-5 also issued under 26 U.S.C. 245A(g), 951A(a), 954(c)(6)(A), and 965(o). Sections 1.245A-6 through 1.245A-11 also issued under 26 U.S.C. 245A(g), 882(c)(1)(A), 951A, 954(b)(5), 954(c)(6), and 965(o). Section 1.245A(d)-1 also issued under 26 U.S.C. 245A(g). Section 1.245A(e)-1 also issued under 26 U.S.C. 245A(g). Section 1.250-0 also issued under 26 U.S.C. 250(c). Section 1.250-1 also issued under 26 U.S.C. 250(c). Section 1.250(a)-1 also issued under 26 U.S.C. 250(c) and 6001. Section 1.250(b)-1 also issued under 26 U.S.C. 250(c) and 6001. Section 1.250(b)-2 also issued under 26 U.S.C. 250(c). Section 1.250(b)-3 also issued under 26 U.S.C. 250(c). Section 1.250(b)-4 also issued under 26 U.S.C. 250(c). Section 1.250(b)-5 also issued under 26 U.S.C. 250(c). Section 1.250(b)-6 also issued under 26 U.S.C. 250(c). Section 1.263A-1 also issued under 26 U.S.C. 263A(j). Section 1.263A-2 also issued under 26 U.S.C. 263A(j). Section 1.263A-3 also issued under 26 U.S.C. 263A(j). Section 1.263A-4 also issued under 26 U.S.C. 263A. Section 1.263A-4T also issued under 26 U.S.C. 263A. Section 1.263A-5 also issued under 26 U.S.C. 263A. Section 1.263A-6 also issued under 26 U.S.C. 263A. Section 1.263A-7 also issued under 26 U.S.C. 263A(j). Section 1.263A-7T also issued under 26 U.S.C. 263A. Sections 1.263A-8 through 1.263A-15 also issued under 26 U.S.C. 263A(j). Sections 1.267A-1 through 1.267A-7 also issued under 26 U.S.C. 267A(e). Section 1.267(a)-3 also issued under 26 U.S.C. 267(a)(3)(A) and (a)(3)(B)(ii). Section 1.267(f)-1 also issued under 26 U.S.C. 267 and 1502. Section 1.269-3(d) also issued under 26 U.S.C. 382(m). Section 1.274-2 also issued under 26 U.S.C. 274(o). Section 1.274-5 also issued under 26 U.S.C. 274(p). Section 1.274-5T also issued under 26 U.S.C. 274(d). Section 1.274-9 also issued under 26 U.S.C. 274(o). Section 1.274-10 also issued under 26 U.S.C. 274(o). Section 1.274-11 also issued under 26 U.S.C. 274. Section 1.274-12 also issued under 26 U.S.C. 274. Section 1.274-13 also issued under 26 U.S.C. 274. Section 1.274-14 also issued under 26 U.S.C. 274. Section 1.274(d)-1 also issued under 26 U.S.C. 274(d). Section 1.274(d)-1T also issued under 26 U.S.C. 274(d). Section 1.280C-4 also issued under 26 U.S.C. 280C(c)(4). Section 1.280F-1T also issued under 26 U.S.C. 280F. Section 1.280F-6 also issued under 26 U.S.C. 280F. Section 1.280F-7 also issued under 26 U.S.C. 280F(c). Section 1.280G-1 also issued under 26 U.S.C. 280G(b) and (e). Section 1.301-1 also issued under 26 U.S.C. 357(d)(3). Section 1.301-1T also issued under 26 U.S.C. 357(d)(3). Section 1.304-5 also issued under 26 U.S.C. 304. Section 1.304-7 also issued under 26 U.S.C. 304(b)(5)(C). Section 1.305-3 also issued under 26 U.S.C. 305. Section 1.305-5 also issued under 26 U.S.C. 305. Section 1.305-7 also issued under 26 U.S.C. 305. Section 1.332-8 also issued under 26 U.S.C. 332(d)(4). Section 1.334-1 also issued under 26 U.S.C. 367(b). Section 1.336-1 is also issued under 26 U.S.C. 336. Section 1.336-2 is also issued under 26 U.S.C. 336. Section 1.336-3 is also issued under 26 U.S.C. 336. Section 1.336-4 is also issued under 26 U.S.C. 336. Section 1.336-5 is also issued under 26 U.S.C. 336. Section 1.337(d)-1 also issued under 26 U.S.C. 337(d). Section 1.337(d)-2 also issued under 26 U.S.C. 337(d). Section 1.337(d)-3 also issued under 26 U.S.C. 337(d). Section 1.337(d)-4 also issued under 26 U.S.C. 337. Section 1.337(d)-5 also issued under 26 U.S.C. 337. Section 1.337(d)-6 also issued under 26 U.S.C. 337. Section 1.337(d)-7 also issued under 26 U.S.C. 337. Section 1.337(d)-7T also issued under 26 U.S.C. 337(d) and 355(h). Section 1.338-1 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-2 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-3 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-4 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-5 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-6 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-7 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-8 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-9 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-10 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338-11 also issued under 26 U.S.C. 338. Section 1.338-11T also issued under 26 U.S.C. 338. Section 1.338(h)(10)-1 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.338(h)(10)-1T also issued under 26 U.S.C. 337(d), 338 and 1502. Section 1.338(i)-1 also issued under 26 U.S.C. 337(d), 338, and 1502. Section 1.351-1 also issued under 26 U.S.C. 351. Section 1.351-2 also issued under 26 U.S.C. 351(g)(4). Section 1.354-1 also issued under 26 U.S.C. 351(g)(4). Section 1.355-1 also issued under 26 U.S.C. 351(g)(4). Section 1.355-2(g) and (i) also issued under 26 U.S.C. 355(b)(3)(D). Section 1.355-2T(g) and (i) are also issued under 26 U.S.C. 355(b)(3)(D). Section 1.355-6 also issued under 26 U.S.C. 355(d)(9). Section 1.355-7 also issued under 26 U.S.C. 355(e)(5). Section 1.355-8 also issued under 26 U.S.C. 336(e), 355(e)(3)(B), 355(e)(5), and 355(f). Section 1.356-6 also issued under 26 U.S.C. 351(g)(4). Section 1.356-7 also issued under 26 U.S.C. 351(g)(4). Section 1.358-2 also issued under 26 U.S.C. 358(b)(1). Section 1.358-5 also issued under 26 U.S.C. 358(h)(2). Section 1.358-5T also issued under 26 U.S.C. 358(h)(2). Section 1.358-7 also issued under Public Law 106-554, 114 Stat. 2763, 2763A-638 (2001). Section 1.362-3 also issued under 26 U.S.C. 367(b). Section 1.362-4 also issued under 26 U.S.C. 362(e)(2)(C)(ii). Section 1.367(a)-1 also issued under 26 U.S.C. 367(a). Section 1.367(a)-1T also issued under 26 U.S.C. 367(a). Section 1.367(a)-3 also issued under 26 U.S.C. 367(a). Section 1.367(a)-3T also issued under 26 U.S.C. 367(a). Section 1.367(a)-7 also issued under 26 U.S.C. 367(a), (b), (c), and 337(d). Section 1.367(a)-8 also issued under 26 U.S.C. 367(a) and (b). Section 1.367(a)-9T also issued under 26 U.S.C. 367(a) and (b). Section 1.367(b)-0 also issued under 26 U.S.C. 367(b). Section 1.367(b)-1 also issued under 26 U.S.C. 367(a) and (b). Section 1.367(b)-2 also issued under 26 U.S.C. 367(a) and (b). Sections 1.367(b)-2(c)(1) and (2) also issued under 26 U.S.C. 367(b)(1) and (2). Section 1.367(b)-2(d)(3) also issued under 26 U.S.C. 367(b)(1) and (2). Section 1.367(b)-3 also issued under 26 U.S.C. 367(a) and (b). Section 1.367(b)-3T also issued under 26 U.S.C. 367(a) and (b). Section 1.367(b)-4 also issued under 26 U.S.C. 367(a) and (b) and 954(c)(6)(A). Section 1.367(b)-4(b)(1) also issued under 26 U.S.C. 367(b). Section 1.367(b)-4(d) also issued under 26 U.S.C. 367(b)(1) and (2). Section 1.367(b)-6 also issued under 26 U.S.C. 367(b). Section 1.367(b)-7 also issued under 26 U.S.C. 367(a) and (b), 26 U.S.C. 902, and 26 U.S.C. 904. Section 1.367(b)-8 also issued under 26 U.S.C. 367(b). Section 1.367(b)-9 also issued under 26 U.S.C. 367(a) and (b), 26 U.S.C. 902, and 26 U.S.C. 904. Section 1.367(b)-10 also issued under 26 U.S.C. 367(b). Section 1.367(b)-12 also issued under 26 U.S.C. 367(a) and (b). Section 1.367(b)-13 also issued under 26 U.S.C. 367(b). Section 1.367(d)-1 also issued under 26 U.S.C. 367(d). Section 1.367(e)-1 also issued under 26 U.S.C. 367(e)(1). Section 1.367(e)-1(a) also issued under 26 U.S.C. 367(e). Section 1.367(e)-2 also issued under 26 U.S.C. 367(e)(2). Section 1.382-1 also issued under 26 U.S.C. 382(m). Section 1.382-2 also issued under 26 U.S.C. 382(k)(1), (l)(3), (m), and 26 U.S.C. 383. Section 1.382-2T also issued under 26 U.S.C. 382(g)(4)(C), (i), (k)(1) and (6), (l)(3), (m), and 26 U.S.C. 383. Section 1.382-3 also issued under 26 U.S.C. 382(g)(4)(C) and 26 U.S.C. 382(m). Section 1.382-4 also issued under 26 U.S.C. 382(l)(3) and 382(m). Section 1.382-5 also issued under 26 U.S.C. 382(m). Section 1.382-5T also issued under 26 U.S.C. 382(m). Section 1.382-6 also issued under 26 U.S.C. 382(b)(3)(A), 26 U.S.C.(d)(1), 26 U.S.C. 382(m), and 26 U.S.C.383(d). Section 1.382-7 also issued under 26 U.S.C 382(m). Section 1.382-7T also issued under 26 U.S.C. 382(m). Section 1.382-8 also issued under 26 U.S.C. 382(m). Section 1.382-9 also issued under 26 U.S.C. 382(l)(3) and (m). Section 1.382-10 also issued under 26 U.S.C 382(m). Section 1.382-10T is also issued under 26 U.S.C. 382(m). Section 1.382-12 also issued under 26 U.S.C. 382(f) and 26 U.S.C. 382(m). Section 1.383-0 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 383. Section 1.383-1 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 383. Section 1.383-2 also issued under 26 U.S.C. 383. Section 1.385-1 also issued under 26 U.S.C. 385. Section 1.385-3 also issued under 26 U.S.C. 385, 701, 1502, 1504(a)(5)(A), and 7701(l). Section 1.385-4 also issued under 26 U.S.C. 385 and 1502. Section 1.401-12 also issued under 26 U.S.C. 401(d)(1). Section 1.401(a)-1 also issued under 26 U.S.C. 401 Section 1.401(a)(2)-1 also issued under Multiemployer Pension Plan Amendments Act, Public Law 96-364, 410, (94 Stat. 1208, 1308)(1980). Section 1.401(a)(5)-1 also issued under 26 U.S.C. 401(a)(5). Section 1.401(a)(9)-1 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-2 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-3 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-4 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-5 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-6 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-7 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-8 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(9)-9 also issued under 26 U.S.C. 401(a)(9). Section 1.401(a)(17)-1 also issued under 26 U.S.C. 401(a)(17). Sections 1.401(a)(26)-1 through (a)(26)-9 also issued under 26 U.S.C. 401(a)(26). Section 1.401(a)(35)-1 is also issued under 26 U.S.C. 401(a)(35). Section 1.401(a)-21 also issued under 26 U.S.C. 401 and section 104 of the Electronic Signatures in Global and National Commerce Act, Public Law 106-229 (114 Stat. 464). Section 1.401(b)-1 also issued under 26 U.S.C. 401(b). Section 1.401(k)-1 also issued under 26 U.S.C. 401(m)(9). Section 1.401(k)-3 is also issued under 26 U.S.C. 401(m)(9). Section 1.401(l)-0 through 1.401(l)-6 also issued under 26 U.S.C. 401(l). Section 1.402A-1 is also issued under 26 U.S.C. 402A Section 1.403(b)-6 also issued under 26 U.S.C. 403(b)(10). Section 1.404(k)-3 is also issued under sections 26 U.S.C. 162(k) and 404(k)(5)(A). Section 1.408-2 also issued under 26 U.S.C. 408(a) and 26 U.S.C. 408(q). Section 1.408-4 also issued under 26 U.S.C. 408. Section 1.408-8 also issued under 26 U.S.C. 408(a)(6) and (b)(3). Section 1.408-11 also issued under 26 U.S.C. 408. Section 1.408(q)-1 also issued under 26 U.S.C. 408(q). Section 1.408A-1 also issued under 26 U.S.C. 408A. Section 1.408A-2 also issued under 26 U.S.C. 408A. Section 1.408A-3 also issued under 26 U.S.C. 408A. Section 1.408A-4 also issued under 26 U.S.C. 408A. Section 1.408A-5 also issued under 26 U.S.C. 408A. Section 1.408A-6 also issued under 26 U.S.C. 408A. Section 1.408A-7 also issued under 26 U.S.C. 408A. Section 1.408A-8 also issued under 26 U.S.C. 408A. Section 1.408A-9 also issued under 26 U.S.C. 408A. Section 1.409(p)-1 is also issued under 26 U.S.C. 409(p)(7). Section 1.410(b)-2 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-3 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-4 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-5 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-6 also issued under 26 U.S.C. 410(b)(6) and section 664 of the Economic Growth and Tax Relief Reconciliation Act of 2001 (Public Law 107-16, 115 Stat. 38). Section 1.410(b)-7 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-8 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-9 also issued under 26 U.S.C. 410(b)(6). Section 1.410(b)-10 also issued under 26 U.S.C. 410(b)(6). Section 1.411(a)-7 also issued under 26 U.S.C. 411(a)(7)(B)(i). Section 1.411(a)(13)-1 also issued under 26 U.S.C. 411(a)(13). Section 1.411(b)(5)-1 also issued under 26 U.S.C. 411(b)(5). Section 1.411(d)-3 also issued under 26 U.S.C. 411(d)(6) and section 645(b) of the Economic Growth and Tax Relief Reconciliation Act of 2001, Public Law 107-16 (115 Stat. 38). Section 1.411(d)-4 also issued under 26 U.S.C. 411(d)(6). Section 1.411(d)-6 issued under Reorganization Plan No. 4 of 1978, 29 U.S.C. 1001nt. §§ 1.414(c)-1 through 1.414(c)-5 also issued under 26 U.S.C. 414(c). Section 1.414(c)-5 also issued under 26 U.S.C. 414(b), (c), and (o). Section 1.414(q)-1T also issued under 26 U.S.C. 414(q). Sections 1.414(r)-0 through 1.414(r)-7 also issued under 26 U.S.C. 414(r). Section 1.414(r)-8 also issued under 26 U.S.C. 410(b) and 414(r). Section 1.414(r)-9 also issued under 26 U.S.C. 401(a)(26) and 414(r). Section 1.414(r)-10 also issued under 26 U.S.C. 129 and 414(r). Section 1.414(r)-1 also issued under 26 U.S.C. 414(r). Section 1.414(s)-1 also issued under 26 U.S.C. 414(s). Section 1.414(v)-2 also issued under 26 U.S.C. 414(v)(7)(D). Section 1.417(e)-1 also issued under 26 U.S.C. 417(e)(3)(A)(ii)(II). Section 1.417(e)-1T also issued under 26 U.S.C. 417(e)(3)(A)(ii)(II). Section 1.419A(f)(6)-1 also issued under 26 U.S.C. 419A(i). Section 1.420-1 also issued under 26 U.S.C. 420(c)(3)(E). Section 1.430(j) 1 also issued under 26 U.S.C. 430(j)(4)(F). Section 1.441-2T also issued under 26 U.S.C. 441(f). Section 1.441-3T also issued under 26 U.S.C. 441. Section 1.442-2T and 1.442-3T also issued under 26 U.S.C. 422, 706, and 1378. Section 1.444-0T through 1.444-3T and Section 1.444-4 is also issued under 26 U.S.C. 444(g). Section 1.446-1 also issued under 26 U.S.C. 446 and 461(h). Section 1.446-4 also issued under 26 U.S.C. 1502. Section 1.446-6 also issued under 26 U.S.C. 446 and 26 U.S.C. 860G. Section 1.446-7 also issued under 26 U.S.C. 446. Section 1.451-3 also issued under 26 U.S.C. 451(b)(1)(A)(ii), (b)(3)(C) and 461(h). Section 1.451-8 also issued under 26 U.S.C. 451(c)(2)(A), (3), (4)(A)(iii), (4)(b)(vii), and 461(h). Section 1.453-11 also issued under 26 U.S.C. 453(j)(1) and (k). Section 1.453A-3 also issued under 26 U.S.C. 453A. Section 1.458-1 also issued under 26 U.S.C. 458. Section 1.460-1 also issued under 26 U.S.C. 460(h). Section 1.460-2 also issued under 26 U.S.C. 460(h). Section 1.460-3 also issued under 26 U.S.C. 460(h). Section 1.460-4 also issued under 26 U.S.C. 460(h) and 1502. Section 1.460-5 also issued under 26 U.S.C. 460(h). Section 1.460-6 also issued under 26 U.S.C. 460(h). Section 1.461-1 also issued under 26 U.S.C. 461(h). Section 1.461-2 also issued under 26 U.S.C. 461(h). Section 1.461-4 also issued under 26 U.S.C. 461(h). Section 1.461-4(d) also issued under 26 U.S.C. 460 and 26 U.S.C. 461(h). Section 1.461-5 also issued under 26 U.S.C. 461(h). Section 1.461-6 also issued under 26 U.S.C. 461(h). Section 1.465-8 also issued under 26 U.S.C. 465. Section 1.465-20 also issued under 26 U.S.C. 465. Section 1.465-27 also issued under 26 U.S.C. 465(b)(6)(B)(iii). Section 1.466-1 through 1.466-4 also issued under 26 U.S.C. 466. Section 1.467-1 is also issued under 26 U.S.C. 467. Section 1.467-2 is also issued under 26 U.S.C. 467. Section 1.467-3 is also issued under 26 U.S.C. 467. Section 1.467-4 is also issued under 26 U.S.C. 467. Section 1.467-5 is also issued under 26 U.S.C. 467. Section 1.467-6 is also issued under 26 U.S.C. 467. Section 1.467-7 is also issued under 26 U.S.C. 467. Section 1.467-8 is also issued under 26 U.S.C. 467. Section 1.467-9 is also issued under 26 U.S.C. 467. Section 1.468A-5 also issued under 26 U.S.C. 468A(e)(5). Section 1.468A-5T also issued under 26 U.S.C. 468A(e)(5). Section 1.468B-1 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-2 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-3 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-4 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-5 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-7 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.468B-9 also issued under 26 U.S.C. 461(h) and 468B(g). Section 1.469-1 also issued under 26 U.S.C. 469. Section 1.469-1T also issued under 26 U.S.C. 469. Section 1.469-2 also issued under 26 U.S.C. 469(l). Section 1.469-2T also issued under 26 U.S.C. 469(l). Section 1.469-3 also issued under 26 U.S.C. 469(l). Section 1.469-3T also issued under 26 U.S.C. 469(l). Section 1.469-4 also issued under 26 U.S.C. 469(l). Section 1.469-5 also issued under 26 U.S.C. 469(l). Section 1.469-5T also issued under 26 U.S.C. 469(l). Section 1.469-7 also issued under 26 U.S.C. 469(l). Section 1.469-9 also issued under 26 U.S.C. 469(c)(6), (h)(2), and (l)(1). Section 1.469-11 also issued under 26 U.S.C. 469(l). Section 1.471 also issued under 26 U.S.C. 471. Section 1.471-3 also issued under 26 U.S.C. 471(a). Section 1.471-4 also issued under 26 U.S.C. 263A. Section 1.471-5 also issued under 26 U.S.C. 263A. Section 1.471-6 also issued under 26 U.S.C. 471. Section 1.472-8 also issued under 26 U.S.C. 472. Section 1.475(a)-3 also issued under 26 U.S.C. 475(e). Section 1.475(a)-4 also issued under 26 U.S.C. 475(g). Section 1.475(b)-1 also issued under 26 U.S.C. 475(b)(4) and 26 U.S.C. 475(e). Section 1.475(b)-2 also issued under 26 U.S.C. 475(b)(2) and 26 U.S.C. 475(e). Section 1.475(b)-4 also issued under 26 U.S.C. 475(b)(2), 26 U.S.C. 475(e), and 26 U.S.C. 6001. Section 1.475(c)-1 also issued under 26 U.S.C. 475(e). Section 1.475(c)-2 also issued under 26 U.S.C. 475(e) and 26 U.S.C. 860G(e). Section 1.475(d)-1 also issued under 26 U.S.C. 475(e). Section 1.475(e)-1 also issued under 26 U.S.C. 475(e). Section 1.481-1 also issued under 26 U.S.C. 481. Section 1.481-2 also issued under 26 U.S.C. 481. Section 1.481-3 also issued under 26 U.S.C. 481. Section 1.481-4 also issued under 26 U.S.C. 481. Section 1.481-5 also issued under 26 U.S.C. 481. Section 1.481-6 is also issued under 26 U.S.C. 481. Section 1.482-1 also issued under 26 U.S.C. 482 and 936. Sections 1.482-1 and 1.482-1T also issued under 26 U.S.C. 482. Section 1.482-2 also issued under 26 U.S.C. 482. Section 1.482-3 also issued under 26 U.S.C. 482. Section 1.482-4 also issued under 26 U.S.C. 482. Section 1.482-5 also issued under 26 U.S.C. 482. Section 1.482-7 is also issued under 26 U.S.C. 482. Section 1.482-9 also issued under 26 U.S.C. 482. Section 1.482-2A also issued under 26 U.S.C. 482. Section 1.482-7A also issued under 26 U.S.C. 482. Section 1.483-1 through 1.483-3 also issued under 26 U.S.C. 483(f). Section 1.483-4 also issued under 26 U.S.C. 483(f). Section 1.501(c)(29)-1 also issued under 26 U.S.C. 501(c)(29)(B)(i). Section 1.501(c)(29)-1T also issued under 26 U.S.C. 501(c)(29)(B)(i). Sections 1.504-1 and 1.504-2 also issued under 26 U.S.C. 504(b). Section 1.514(c)-2 also issued under 26 U.S.C. 514(c)(9)(E)(iii). Section 1.527-9 also issued under 26 U.S.C. 527(h)(2)(B)(i). Sections 1.529A-0 through 1.529A-8 also issued under 26 U.S.C. 529A(g). Section1.585-5 through 1.585-8 also issued under 26 U.S.C. 585(b)(3). Section1.597-1 through 1.597-7 also issued under 26 U.S.C. 597 and 1502. Section1.597-8 also issued under 26 U.S.C. 597. Section 1.642(c)-6 also issued under 26 U.S.C. 642(c)(5). Section 1.642(h)-2 also issued under 26 U.S.C. 642(h). Section 1.642(h)-5 also issued under 26 U.S.C. 642(h). Section 1.643(a)-8 also issued under 26 U.S.C. 643(a)(7). Section 1.643(f)-1 also issued under 26 U.S.C. 643(f). Section 1.643(h)-1 also issued under 26 U.S.C. 643(a)(7). Section 1.642(c)-6A also issued under 26 U.S.C. 642(c)(5). Section 1.645-1 also issued under 26 U.S.C. 645. Sections 1.663(c)-1, 1.663(c)-2, 1.663(c)-3, 1.663(c)-4, 1.663(c)-5, and 1.663(c)-6 also issued under 26 U.S.C. 663(c). Section 1.664-1 also issued under 26 U.S.C. 664(a). Section 1.664-2 also issued under 26 U.S.C. 664(a). Section 1.664-3 also issued under 26 U.S.C. 664(a). Section 1.664-4 also issued under 26 U.S.C. 664(a). Section 1.664-4A also issued under 26 U.S.C. 664(a). Section 1.671-2 also issued under 26 U.S.C. 643(a)(7) and 672(f)(6). Section 1.672(f)-1 also issued under 26 U.S.C. 643(a)(7) and 672(f)(6). Section 1.672(f)-2 also issued under 26 U.S.C. 643(a)(7) and 672(f)(3) and (6). Section 1.672(f)-3 also issued under 26 U.S.C. 643(a)(7) and 672(f)(2) and (6). Section 1.672(f)-4 also issued under 26 U.S.C. 643(a)(7) and 672(f)(4) and (6). Section 1.672(f)-5 also issued under 26 U.S.C. 643(a)(7) and 672(f)(6). Section 1.679-1 also issued under 26 U.S.C. 643(a)(7) and 679(d). Section 1.679-2 also issued under 26 U.S.C. 643(a)(7) and 679(d). Section 1.679-3 also issued under 26 U.S.C. 643(a)(7) and 679(d). Section 1.679-4 also issued under 26 U.S.C. 643(a)(7), 679(a)(3) and 679(d). Section 1.679-5 also issued under 26 U.S.C. 643(a)(7) and 679(d). Section 1.679-6 also issued under 26 U.S.C. 643(a)(7) and 679(d). Section 1.684-1 also issued under 26 U.S.C. 643(a)(7) and 684(a). Section 1.684-2 also issued under 26 U.S.C. 643(a)(7) and 684(a). Section 1.684-3 also issued under 26 U.S.C. 643(a)(7) and 684(a). Section 1.684-4 also issued under 26 U.S.C. 643(a)(7) and 684(a). Section 1.684-5 also issued under 26 U.S.C. 643(a)(7) and 684(a). Section 1.701-2 also issued under 26 U.S.C. 701 through 761. Section 1.704-3 also issued under 26 U.S.C. 704(c). Section 1.704-4 also issued under 26 U.S.C. 704(c). Section 1.705-2 also issued under 26 U.S.C. 705 and 1032. Section 1.706-1T also issued under 26 U.S.C. 706(b). Section 1.706-3 also issued under 26 U.S.C. 170(h)(7)(G). Section 1.706-3T also issued under 26 U.S.C. 444(f). Section 1.706-4 also issued under 26 U.S.C. 170(h)(7)(G). Sections 1.707-2 through 1.707-9 also issued under 26 U.S.C. 707(a)(2). Section 1.721-1 also issued under 26 U.S.C. 721. Section 1.721(c)-1 also issued under 26 U.S.C. 721(c). Section 1.721(c)-2 also issued under 26 U.S.C. 721(c). Section 1.721(c)-3 also issued under 26 U.S.C. 721(c). Section 1.721(c)-4 also issued under 26 U.S.C. 721(c). Section 1.721(c)-5 also issued under 26 U.S.C. 721(c). Section 1.721(c)-6 also issued under 26 U.S.C. 721(c). Section 1.721(c)-7 also issued under 26 U.S.C. 721(c). Section 1.731-2 also issued under 26 U.S.C. 731(c). Section 1.732-1 also issued under 26 U.S.C. 732. Section 1.732-2 also issued under 26 U.S.C. 732. Section 1.732-3 also issued under 26 U.S.C. 337(d), 732(f)(8), and 1502. Section 1.734-1 also issued under 26 U.S.C. 734. Section 1.743-1 also issued under 26 U.S.C. 743. Section 1.751-1 also issued under 26 U.S.C. 751. Section 1.752-1(a) also issued under Public Law 106-554, 114 Stat. 2763, 2763A-638 (2001). Section 1.752-6 also issued under Public Law 106-554, 114 Stat. 2763, 2763A-638 (2001). Section 1.752-7 also issued under Public Law 106-554, 114 Stat. 2763, 2763A-638 (2001). Section 1.754-1 also issued under 26 U.S.C. 754. Section 1.755-1 also issued under 26 U.S.C. 755. Section 1.755-2 also issued under 26 U.S.C. 755 and 26 U.S.C. 1060. Section 1.761-2 also issued under 26 U.S.C. 446(b), 761(a), 6031(a), 6417(d), and 6417(h). Section 1.807-2 also issued under 26 U.S.C. 817A(e). Section 1.807-3 also issued under 26 U.S.C. 807(e)(6). Section 1.809-10 also issued under 26 U.S.C. 809(b)(2) and (g)(3). Section 1.811-3 also issued under 26 U.S.C. 817A(e). Section 1.812-9 also issued under 26 U.S.C. 817A(e). Section 1.817-5 also issued under 26 U.S.C. 817(h). Section 1.817A-1 also issued under 26 U.S.C. 817A(e). Section 1.832-4 also issued under 26 U.S.C. 832(b)(5)(A). Section 1.846-1 also issued under 26 U.S.C. 846. Section 1.848-2 also issued under 26 U.S.C. 845(b) and 26 U.S.C. 848(d)(4)(B). Section 1.848-3 also issued under 26 U.S.C. 848(d)(4)(B). Sections 1.851-3 and 1.851-5 are also issued under 26 U.S.C. 851(c). Section 1.852-11 is also issued under 26 U.S.C. 852(b)(3)(C), 852(b)(8), and 852(c). Section 1.853-1 also issued under 26 U.S.C. 901(j). Section 1.853-2 also issued under 26 U.S.C. 901(j). Section 1.853-3 also issued under 26 U.S.C. 901(j). Section 1.853-4 also issued under 26 U.S.C. 901(j) and 26 U.S.C. 6011. Section 1.860A-0 also issued under 26 U.S.C. 860G(e). Section 1.860A-1 also issued under 26 U.S.C. 860G(b) and 860G(e). Section 1.860C-2 also issued under 26 U.S.C. 860C(b)(1) and 860G(e). Section 1.860D-1 also issued under 26 U.S.C. 860G(e). Section 1.860E-1 also issued under 26 U.S.C. 860E and 860G(e). Section 1.860E-2 also issued under 26 U.S.C. 860E(e). Section 1.860F-2 also issued under 26 U.S.C. 860G(e). Section 1.860F-4 also issued under 26 U.S.C. 860G(e) and 26 U.S.C. 6230(k). Section 1.860F-4T also issued under 26 U.S.C. 860G(c)(3) and (e). Section 1.860G-1 also issued under 26 U.S.C. 860G(a)(1)(B), (d)(2)(E), and (e). Section 1.860G-2 also issued under 26 U.S.C. 860G(e). Section 1.860G-3 also issued under 26 U.S.C. 860G(b) and 26 U.S.C. 860G(e). Section 1.861-2 also issued under 26 U.S.C. 863(a). Section 1.861-3 also issued under 26 U.S.C. 863(a). Section 1.861-8 also issued under 26 U.S.C. 250(c), 26 U.S.C. 864(e)(7), and 26 U.S.C. 882(c). Section 1.861-8T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-9 also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), 987, and 989(c), and 7701(f). Section 1.861-9T also issued under 26 U.S.C. 861, 863(a), 864(e), 864(e)(7), 865(i), and 7701(f). Section 1.861-10(e) also issued under 26 U.S.C. 863(a), 26 U.S.C. 864(e)(7), 26 U.S.C. 865(i), and 26 U.S.C. 7701(f). Section 1.861-10T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-11 also issued under 26 U.S.C. 863(a), 26 U.S.C. 864(e)(7), 26 U.S.C. 865(i), and 26 U.S.C. 7701(f). Section 1.861-11T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-12 also issued under 26 U.S.C. 864(e)(7). Section 1.861-12T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-13 also issued under 26 U.S.C. 864(e)(7). Section 1.861-13T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-14 also issued under 26 U.S.C. 864(e)(7). Section 1.861-14T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). Section 1.861-17 also issued under 26 U.S.C. 864(e)(7). Section 1.863-1 also issued under 26 U.S.C. 863(a). Section 1.863-2 also issued under 26 U.S.C. 863. Section 1.863-3 also issued under 26 U.S.C. 863(a) and (b), and 26 U.S.C. 936(h). Section 1.863-4 also issued under 26 U.S.C. 863. Section 1.863-6 also issued under 26 U.S.C. 863. Section 1.863-7 also issued under 26 U.S.C. 863(a) and 871(m). Section 1.863-8 also issued under 26 U.S.C. 863(a), (b) and (d). Section 1.863-9 also issued under 26 U.S.C. 863(a), (d) and (e). Section 1.864-5 also issued under 26 U.S.C. 7701(l). Section 1.864-8T also issued under 26 U.S.C. 864(d)(8). Section 1.864(c)(8)-1 also issued under 26 U.S.C. 864(c)(8) and 897(g). Section 1.864(c)(8)-2 also issued under 26 U.S.C. 864(c)(8)(E), 6001 and 6031(b). Section 1.865-1 also issued under 26 U.S.C. 863(a) and 865(j)(1). Section 1.865-2 also issued under 26 U.S.C. 863(a) and 865(j)(1). Section 1.865-3 also issued under 26 U.S.C. 865(j). Section 1.871-1 also issued under 26 U.S.C. 7701(l). Section 1.871-7 also issued under 26 U.S.C. 7701(l). Section 1.871-9 also issued under 26 U.S.C. 7701(b)(11). Sections 1.871-15 and 1.871-15T also issued under 26 U.S.C. 871(m). Section 1.874-1 also issued under 26 U.S.C. 874. Section 1.881-2 also issued under 26 U.S.C. 7701(l). Section 1.881-3 also issued under 26 U.S.C. 7701(l). Section 1.881-4 also issued under 26 U.S.C. 7701(l). Section 1.882-4 also issued under 26 U.S.C. 882(c). Section 1.882-5 also issued under 26 U.S.C. 882(c), 26 U.S.C. 864(e), 26 U.S.C. 988(d), and 26 U.S.C. 7701(l). Section 1.883-1 is also issued under 26 U.S.C. 883. Section 1.883-2 is also issued under 26 U.S.C. 883. Section 1.883-3 is also issued under 26 U.S.C. 883. Section 1.883-4 is also issued under 26 U.S.C. 883. Section 1.883-5 is also issued under 26 U.S.C. 883. Section 1.884-0 also issued under 26 U.S.C. 884 (g). Section 1.884-1 also issued under 26 U.S.C. 884. Section 1.884-1 also issued under 26 U.S.C. 884 (g). Section 1.884-1 (d) also issued under 26 U.S.C. 884 (c) (2) (A). Section 1.884-1 (d) (13) (i) also issued under 26 U.S.C. 884 (c) (2). Section 1.884-1 (e) also issued under 26 U.S.C. 884 (c) (2) (B). Section 1.884-2 also issued under 26 U.S.C. 884(g). Section 1.884-2T also issued under 26 U.S.C. 884 (g). Section 1.884-4 also issued under 26 U.S.C. 884 (g). Section 1.884-5 also issued under 26 U.S.C. 884 (g). Section 1.884-5 (e) and (f) also issued under 26 U.S.C. 884 (e) (4) (C). Section 1.892-1T also issued under 26 U.S.C. 892(c). Section 1.892-2T also issued under 26 U.S.C. 892(c). Section 1.892-3 also issued under 26 U.S.C. 892(c). Section 1.892-3T also issued under 26 U.S.C. 892(c). Section 1.892-4 also issued under 26 U.S.C. 892(c). Section 1.892-4T also issued under 26 U.S.C. 892(c). Section 1.892-5 also issued under 26 U.S.C. 892(c). Section 1.892-5T also issued under 26 U.S.C. 892(c). Section 1.892-6T also issued under 26 U.S.C. 892(c). Section 1.892-7T also issued under 26 U.S.C. 892(c). Section 1.894-1 also issued under 26 U.S.C. 894 and 7701(l). Section 1.897-1 also issued under 26 U.S.C. 897 and 897(l)(3). Section 1.897-2 also issued under 26 U.S.C. 897. Sections 1.897-5T, 1.897-6T and 1.897-7T also issued under 26 U.S.C. 897 (d), (e), (g) and (j) and 26 U.S.C. 367(e)(2). Section 1.897-7 also issued under 26 U.S.C. 897(g). Section 1.897(l)-1 also issued under 26 U.S.C. 897(l). Section 1.901(j)-1 also issued under 26 U.S.C. 901(j)(4). Sections 1.901(m)-1 through 1.901-8 also issued under 26 U.S.C. 901(m)(7). Section 1.901(m)-5 also issued under 26 U.S.C. 901(m)(3)(B)(ii). Sections 1.902-1 and 902-2 also issued under 26 U.S.C. 902(c)(7). Section 1.904-1 also issued under 26 U.S.C. 904(d)(7). Section 1.904-2 also issued under 26 U.S.C. 904(d)(7). Section 1.904-3 also issued under 26 U.S.C. 904(d)(7). Section 1.904-4 also issued under 26 U.S.C. 250(c), 26 U.S.C. 865(j), 26. U.S.C. 904(d)(2)(J)(i), 26 U.S.C. 904(d)(6)(C), 26 U.S.C. 904(d)(7), and 26 U.S.C. 951A(f)(1)(B). Section 1.904-5 also issued under 26 U.S.C. 904(d)(7) and 26 U.S.C. 951A(f)(1)(B). Section 1.904-6 also issued under 26 U.S.C. 904(d)(7). Section 1.904-7 also issued under 26 U.S.C. 904(d)(6). Section 1.904(b)-1 also issued under 26 U.S.C. 1(h)(11)(C)(iv) and 904(b)(2)(C). Section 1.904(b)-2 also issued under 26 U.S.C. 1(h)(11)(C)(iv) and 904(b)(2)(C). Section 1.904(f)-(2) also issued under 26 U.S.C. 904 (f)(3)(b). Section 1.904(g)-3 also issued under 26 U.S.C. 904(g)(4). Section 1.904(g)-3T also issued under 26 U.S.C. 904(g)(4). Section 1.904(i)-1 also issued under 26 U.S.C. 904(i). Section 1.905-3 also issued under 26 U.S.C. 989(c)(4). Sections 1.905-3T and 1.905-4T also issued under 26 U.S.C. 989(c)(4). Section 1.905-4 also issued under 26 U.S.C. 989(c)(4), 26 U.S.C. 6227(d), 26 U.S.C. 6241(11), and 26 U.S.C. 6689(a). Section 1.907(b)-1 is also issued under 26 U.S.C. 907(b). Section 1.907(b)-1T also issued under 26 U.S.C. 907(b). Sections 1.909-1 through 1.906-6 also issued under 26 U.S.C. 909(e). Section 1.911-7 also issued under 26 U.S.C. 911(d)(9). Section 1.931-1 also issued under 26 U.S.C. 7654(e). Section 1.932-1 also issued under 26 U.S.C. 7654(e). Section 1.934-1 also issued under 26 U.S.C. 934(b)(4). Section 1.935-1 also issued under 26 U.S.C. 7654(e). Section 1.936-4 also issued under 26 U.S.C. 936(h). Section 1.936-5 also issued under 26 U.S.C. 936(h). Section 1.936-6 also issued under 26 U.S.C. 863(a) and (b), and 26 U.S.C. 936(h). Section 1.936-7 also issued under 26 U.S.C. 936(h). Section 1.936-11 also issued under 26 U.S.C. 936(j). Section 1.937-1 also issued under 26 U.S.C. 937(a). Section 1.937-1T also issued under 26 U.S.C. 937(a). Section 1.937-2 also issued under 26 U.S.C. 937(b). Section 1.937-3 also issued under 26 U.S.C. 937(b). Section 1.951-1 also issued under 26 U.S.C. 7701(a). Section 1.951A-2 also issued under 26 U.S.C. 882(c)(1)(A) and 954(b)(5). Section 1.951A-3 also issued under 26 U.S.C. 951A(d)(4). Section 1.951A-5 also issued under 26 U.S.C. 951A(f)(1)(B). Section 1.952-11T is also issued under 26 U.S.C. 852(b)(3)(C), 852(b)(8), and 852(c). Section 1.953-2 also issued under 26 U.S.C. 7701(b)(11). Section 1.954-0 also issued under 26 U.S.C. 954 (b) and (c). Section 1.954-1 also issued under 26 U.S.C. 954 (b) and (c). Section 1.954-2 also issued under 26 U.S.C. 954 (b) and (c). Section 1.956-1 also issued under 26 U.S.C. 245A(g), 956(d), and 956(e). Section 1.956-1T also issued under 26 U.S.C. 956(d) and 956(e). Section 1.956-2 also issued under 26 U.S.C. 956(d) and 956(e). Section 1.956-3 also issued under 26 U.S.C. 864(d)(8) and 956(e). Section 1.956-4 also issued under 26 U.S.C. 956(d) and 956(e). Section 1.957-1 also issued under 26 U.S.C. 957. Section 1.957-3 also issued under 26 U.S.C. 957(c). Section 1.960-1 also issued under 26 U.S.C. 960(f). Section 1.960-2 also issued under 26 U.S.C. 960(f). Section 1.960-3 also issued under 26 U.S.C. 960(f). Section 1.960-4 also issued under 26 U.S.C. 951A(f)(1)(B) and 26 U.S.C. 960(f). Section 1.962-1 also issued under 26 U.S.C. 965(o). Section 1.965-1 also issued under 26 U.S.C. 965(c)(3)(B)(iii)(V), 965(d)(2), 965(o), 989(c), and 7701(a). Section 1.965-2 also issued under 26 U.S.C. 965(b)(3)(A)(ii), 965(o), and 961(a) and (b). Section 1.965-3 also issued under 26 U.S.C. 965(c)(3)(D) and 965(o). Section 1.965-4 also issued under 26 U.S.C. 965(c)(3)(F) and 965(o). Sections 1.965-5 through 1.965-6 also issued under 26 U.S.C. 965(o) and 26 U.S.C. 902(c)(8) (as in effect on December 21, 2017). Section 1.965-7 also issued under 26 U.S.C. 965(h)(3), 965(h)(5), 965(i)(2), 965(i)(8)(B), 965(m)(2)(A), 965(n)(3), and 965(o). Section 1.965-8 also issued under 26 U.S.C. 965(o). Section 1.965-9 also issued under 26 U.S.C. 965(o). Section 1.985-0 also issued under 26 U.S.C. 985. Section 1.985-1 also issued under 26 U.S.C. 985. Section 1.985-2 also issued under 26 U.S.C. 985. Section 1.985-3 also issued under 26 U.S.C. 985. Section 1.985-4 also issued under 26 U.S.C. 985. Section 1.985-5 also issued under 26 U.S.C. 985, 987, and 989. Section 1.986(a)-1 also issued under 26 U.S.C. 986(a)(1)(C) and 26 U.S.C. 986(a)(1)(D)(ii). Section 1.986(c)-1 also issued under 26 U.S.C. 965(o) and 26 U.S.C. 989(c). Section 1.987-1 also issued under 26 U.S.C. 987, 989, and 1502. Section 1.987-2 also issued under 26 U.S.C. 987, 989, and 1502. Section 1.987-3 also issued under 26 U.S.C. 987 and 989. Section 1.987-4 also issued under 26 U.S.C. 987 and 989. Section 1.987-5 also issued under 26 U.S.C. 987 and 989. Section 1.987-6 also issued under 26 U.S.C. 904, 987, and 989. Section 1.987-7 also issued under 26 U.S.C. 987 and 989. Section 1.987-8 also issued under 26 U.S.C. 987 and 989. Section 1.987-9 also issued under 26 U.S.C. 987, 989, and 6001. Section 1.987-10 also issued under 26 U.S.C. 987, 989, and 6001. Section 1.987-11 also issued under 26 U.S.C. 987, 989, and 1502. Section 1.987-12 also issued under 26 U.S.C. 987 and 989. Section 1.987-13 also issued under 26 U.S.C. 987 and 989. Section 1.987-14 also issued under 26 U.S.C. 987 and 989. Section 1.987-15 also issued under 26 U.S.C. 987 and 989. Section 1.988-0 also issued under 26 U.S.C. 988. Section 1.988-1 also issued under 26 U.S.C. 988 and 989. Section 1.988-2 also issued under 26 U.S.C. 988. Section 1.988-3 also issued under 26 U.S.C. 988. Section 1.988-4 also issued under 26 U.S.C. 988 and 989. Section 1.988-5 also issued under 26 U.S.C. 988. Sections 1.989(a)-0T and 1.989(a)-1T also issued under 26 U.S.C. 989(c). Section 1.989(a)-1 also issued under 26 U.S.C. 989. Section 1.989(b)-1 also issued under 26 U.S.C. 989(b). Section 1.989-1(c) also issued under 26 U.S.C. 989(c). Section 1.1001-6 also issued under 26 U.S.C. 148(i), 26 U.S.C. 988(d), 26 U.S.C. 1275(d), and 26 U.S.C. 7701(l). Section 1.1014-1 also issued under 26 U.S.C. 1014(f). Section 1.1014-2 also issued under 26 U.S.C. 1014(f). Section 1.1014-10 also issued under 26 U.S.C. 1014(f). Section 1.1036-1 also issued under 26 U.S.C. 351(g)(4). Section 1.1059(e)-1 also issued under 26 U.S.C. 1059 (e)(1) and (e)(2). Section 1.1060-1 also issued under 26 U.S.C. 1060. Section 1.1061-0 added under 26 U.S.C. 1061(f). Section 1.1061-1 added under 26 U.S.C. 1061(f). Section 1.1061-2 added under 26 U.S.C. 1061(f). Section 1.1061-3 added under 26 U.S.C. 1(h)(9) and 1061(f). Section 1.1061-4 added under 26 U.S.C. 1061(f). Section 1.1061-5 added under 26 U.S.C. 1061(f). Section 1.1061-6 added under 26 U.S.C. 1061(f). Sections 1.1092(b)-1T and 1.1092(b)-2T also issued under 26 U.S.C. 1092 (b)(1). Section 1.1092(b)-4T also issued under 26 U.S.C. 1092(b)(2). Section 1.1092(b)-6 also issued under 26 U.S.C. 1092(b)(1). Section 1.1092(b)-6 also issued under 26 U.S.C. 1092(b)(2). Section 1.1092(c)-1 also issued under 26 U.S.C. 1092(c)(4)(H). Section 1.1092(c)-2 also issued under 26 U.S.C. 1092(c)(4)(H). Section 1.1092(c)-3 also issued under 26 U.S.C. 1092(c)(4)(H). Section 1.1092(c)-4 also issued under 26 U.S.C. 1092(c)(4)(H). Section 1.1092(d)-1 also issued under 26 U.S.C. 1092(b)(1). Section 1.1092(d)-2 also issued under 26 U.S.C. 1092(d)(3)(B). Section 1.1202-2 is also issued under 26 U.S.C. 1202(k). Section 1.1221-2 also issued under 26 U.S.C. 1221(b)(2)(A)(iii), (b)(2)(B), and (b)(3); 1502 and 6001. Section 1.1244(e)-1 also issued under 26 U.S.C. 1244(e). Section 1.1248-8 also issued under 26 U.S.C. 1248(a) and (c)(1) and (2). Section 1.1254-1 also issued under 26 U.S.C. 1254(b). Section 1.1254-2 also issued under 26 U.S.C. 1254(b). Section 1.1254-3 also issued under 26 U.S.C. 1254(b). Section 1.1254-4 also issued under 26 U.S.C. 1254(b). Section 1.1254-5 also issued under 26 U.S.C. 1254(b). Section 1.1254-6 also issued under 26 U.S.C. 1254(b). Section 1.1271-1 also issued under 26 U.S.C. 1275(d). Section 1.1272-1 also issued under 26 U.S.C. 1275(d). Section 1.1272-2 also issued under 26 U.S.C. 1275(d). Section 1.1272-3 also issued under 26 U.S.C. 1275(d). Section 1.1273-1 also issued under 26 U.S.C. 1275(d). Section 1.1273-2 also issued under 26 U.S.C. 1275(d). Section 1.1274-1 also issued under 26 U.S.C. 1275(d). Section 1.1274-2 also issued under 26 U.S.C. 1275(d). Section 1.1274-3 also issued under 26 U.S.C. 1275(d). Section 1.1274-4 also issued under 26 U.S.C. 1275(d). Section 1.1274-5 also issued under 26 U.S.C. 1275(d). Section 1.1274A-1 also issued under 26 U.S.C. 1274A(e) and 26 U.S.C. 1275(d). Section 1.1275-1 also issued under 26 U.S.C. 1275(d). Section 1.1275-2 also issued under 26 U.S.C. 1275(d). Section 1.1275-3 also issued under 26 U.S.C. 1275(d). Section 1.1275-4 also issued under 26 U.S.C. 1275(d). Section 1.1275-5 also issued under 26 U.S.C. 1275(d). Section 1.1275-6 also issued under 26 U.S.C. 1275(d). Section 1.1275-7 also issued under 26 U.S.C. 1275(d). Section 1.1286-1 also issued under 26 U.S.C. 1275(D) and 1286(f). Section 1.1286-2 also issued under 26 U.S.C. 1286(f). Section 1.1287-1 also issued under 26 U.S.C. 165 (j)(3). Section 1.1291-1 also issued under 26 U.S.C. 1291. Section 1.1291-1 also issued under 26 U.S.C. 1298(a) and (g). Section 1.1291-9, also issued under 26 U.S.C. 1298(a) and (g). Section 1.1298-1 also issued under 26 U.S.C. 1298(f). Section 1.1291-9 also issued under 26 U.S.C. 1291(d)(2). Section 1.1291-10 also issued under 26 U.S.C. 1291(d)(2). Section 1.1293-1 also issued under 26 U.S.C. 1293. Section 1.1294-1T also issued under 26 U.S.C. 1294. Section 1.1295-1 also issued under 26 U.S.C. 1295. Section 1.1295-3 also issued under 26 U.S.C. 1295. Section 1.1296-1 also issued under 26 U.S.C. 1296(g) and 26 U.S.C. 1298(f). Section 1.1296(e)-1 also issued under 26 U.S.C. 1296(e). Section 1.1297-1 also issued under 26 U.S.C. 1298(g). Section 1.1297-2 also issued under 26 U.S.C. 1298(g). Section 1.1297-3T also issued under 26 U.S.C. 1297(b)(1). Section 1.1297-4 also issued under 26 U.S.C. 1297(b)(2)(B) and 1298(g). Section 1.1297-5 also issued under 26 U.S.C. 1297(b)(2)(B) and 1298(g). Section 1.1297-6 also issued under 26 U.S.C. 1297(b)(2)(B) and 1298(g). Section 1.1298-1T also issued under 26 U.S.C. 1298(f) and (g). Section 1.1298-2 also issued under 26 U.S.C. 1298(b)(3) and (g). Section 1.1298-4 also issued under 26 U.S.C. 1298(g). Section 1.1301-1 also issued under 26 U.S.C. 1301(c). Section 1.1301-1T also issued under 26 U.S.C. 1301(c). Section 1.1361-1(j) (6), (10) and (11) also issued under 26 U.S.C. 1361(d)(2)(B)(iii). Section 1.1361-1(l) also issued under 26 U.S.C. 1361(c)(5)(C). Sections 1.1362-1, 1.1362-2, 1.1362-3, 1.1362-4, 1.1362-5, 1.1362-6, 1.1362-7, and 1.1363-1 also issued under 26 U.S.C. 1377. Section 1.1363-2 also issued under 26 U.S.C. 337(d). Section 1.1368-1(f) and (g) also issued under 26 U.S.C. 1377(c). Section 1.1368-2(b) also issued under 26 U.S.C. 1368(c). Section 1.1374-1 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-2 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-3 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-4 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-5 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-6 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-7 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-8 also issued under 26 U.S.C. 337(d) and 1374(e). Section 1.1374-8 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-8T also issued under 26 U.S.C. 337(d) and 1374(e). Section 1.1374-9 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-10 also issued under 26 U.S.C. 337(d) and 1374(e). Section 1.1374-10 also issued under 26 U.S.C. 1374(e) and 337(d). Section 1.1374-10T also issued under 26 U.S.C. 337(d) and 1374(e). Section 1.1377-1 also issued under 26 U.S.C. 1377(a)(2) and (c). Section 1.1394-1 also issued under 26 U.S.C. 1397D. Section 1.1396-1 also issued under 26 U.S.C. 1397D. Section 1.1397E-1 also issued under 26 U.S.C. 1397E. Section 1.1400Z2(a)-1 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1400Z2(b)-1 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1400Z2(c)-1 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1400Z2(d)-1 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1400Z2(d)-2 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1400Z2(f)-1 also issued under 26 U.S.C. 1400Z-2(e)(4). Section 1.1402 (e)-5T also is issued under 26 U.S.C. 1402(e)(1) and (2). Section 1.1411-10 also issued under 26 U.S.C. 367. Section 1.1441-2 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1441-3 also issued under 26 U.S.C. 1441(c)(4), 26 U.S.C. 3401(a)(6) and 26 U.S.C. 7701(l). Section 1.1441-4 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1441-5 also issued under 26 U.S.C. 1441(c)(4), 26 U.S.C. 3401(a)(6) and 26 U.S.C. 7701(b)(11). Section 1.1441-6 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1441-7 also issued under 26 U.S.C. 1441(c)(4), 26 U.S.C. 3401(a)(6) and 26 U.S.C. 7701(l). Section 1.1443-1 also issued under 26 U.S.C. 1443(a). Section 1.1445-2 also issued under 26 U.S.C. 1445. Section 1.1445-5 also issued under 26 U.S.C. 1445(e)(7). Section 1.1445-8 also issued under 26 U.S.C. 1445(e)(7). Section 1.1446-3 also issued under 26 U.S.C. 1446(g). Section 1.1446-4 also issued under 26 U.S.C. 1446(g). Section 1.1446(f)-1 also issued under 26 U.S.C. 1446(f)(6) and 1446(g). Section 1.1446(f)-2 also issued under 26 U.S.C. 1446(f)(6) and 1446(g). Section 1.1446(f)-3 also issued under 26 U.S.C. 1446(f)(6) and 1446(g). Section 1.1446(f)-4 also issued under 26 U.S.C. 1446(f)(6) and 1446(g). Section 1.1446(f)-5 also issued under 26 U.S.C. 1446(f)(6) and 1446(g). Section 1.1461-1 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1461-2 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1462-1 also issued under 26 U.S.C. 1441(c)(4) and 26 U.S.C. 3401(a)(6). Section 1.1471-1 is also issued under 26 U.S.C. 1471 Section 1.1471-2 is also issued under 26 U.S.C. 1471 Section 1.1471-3 is also issued under 26 U.S.C. 1471 Section 1.1471-4 is also issued under 26 U.S.C. 1471 Section 1.1471-5 is also issued under 26 U.S.C. 1471 Section 1.1471-6 is also issued under 26 U.S.C. 1471 Section 1.1472-1 is also issued under 26 U.S.C. 1472 Section 1.1473-1 is also issued under 26 U.S.C. 1473 Section 1.1474-1 is also issued under 26 U.S.C. 1474 Section 1.1474-2 is also issued under 26 U.S.C. 1474 Section 1.1474-3 is also issued under 26 U.S.C. 1474 Section 1.1474-4 is also issued under 26 U.S.C. 1474 Section 1.1474-5 is also issued under 26 U.S.C. 1474 Section 1.1474-6 is also issued under 26 U.S.C. 1474 Section 1.1474-7 is also issued under 26 U.S.C. 1474 Section 1.1502-0 also issued under 26 U.S.C. 1502. Section 1.1502-1 also issued under 26 U.S.C. 1502. Section 1.1502-2 also issued under 26 U.S.C. 1502. Section 1.1502-3 also issued under 26 U.S.C. 1502. Section 1.1502-4 also issued under 26 U.S.C. 1502. Section 1.1502-9 also issued under 26 U.S.C. 1502. Section 1.1502-11 also issued under 26 U.S.C. 1502. Section 1.1502-12 also issued under 26 U.S.C. 250(c) and 1502. Section 1.1502-13 also issued under 26 U.S.C. 250(c), 987, 989, and 1502. Section 1.1502-14Z also issued under 26 U.S.C. 1400Z-2(e)(4) and 1502. Section 1.1502-15 also issued under 26 U.S.C. 1502. Section 1.1502-17 also issued under 26 U.S.C. 446 and 1502. Section 1.1502-18 also issued under 26 U.S.C. 1502. Section 1.1502-19 also issued under 26 U.S.C. 301, 1502, and 1503. Section 1.1502-20 also issued under 26 U.S.C. 337(d) and 1502. Section 1.1502-20T also issued under 26 U.S.C. 337(d) and 1502. Section 1.1502-21 also issued under 26 U.S.C. 1502 and 6402(i). Section 1.1502-21(b)(1) and (b)(3)(v) also issued under 26 U.S.C. 1502. Section 1.1502-21T also issued under 26 U.S.C. 1502. Section 1.1502-21T(b)(1) and (b)(3)(v) also issued under 26 U.S.C. 1502. Section 1.1502-22 also issued under 26 U.S.C. 1502. Section 1.1502-23 also issued under 26 U.S.C. 1502. Section 1.1502-26 also issued under 26 U.S.C. 1502. Section 1.1502-28 also issued under 26 U.S.C. 1502. Section 1.1502-30 also issued under 26 U.S.C. 1502. Section 1.1502-31 also issued under 26 U.S.C. 1502. Section 1.1502-32 also issued under 26 U.S.C. 301, 1502, and 1503. Section 1.1502-32 also issued under 26 U.S.C. 1502. Section 1.1502-32(a)(2), (b)(3)(iii)(C), (b)(3)(iii)(D), and (b)(4)(vi) also issued under 26 U.S.C. 1502. Section 1.1502-32T also issued under 26 U.S.C. 1502. Section 1.1502-33 also issued under 26 U.S.C. 1502. Section 1.1502-34 also issued under 26 U.S.C. 1502. Section 1.1502-35 also issued under 26 U.S.C. 1502. Section 1.1502-35T also issued under 26 U.S.C. 1502. Section 1.1502-36 also issued under 26 U.S.C. 1502. Section 1.1502-36 also issued under 26 U.S.C. 337(d). Section 1.1502-43 also issued under 26 U.S.C. 1502. Section 1.1502-47 also issued under 26 U.S.C. 1502, 1503(c) and 1504(c). Section 1.1502-50 also issued under 26 U.S.C. 250(c) and 1502. Section 1.1502-51 also issued under 26 U.S.C. 1502. Section 1.1502-55 also issued under 26 U.S.C. 1502. Section 1.1502-59A also issued under 26 U.S.C. 1502. Section 1.1502-68 also issued under 26 U.S.C. 1502. Section 1.1502-75 also issued under 26 U.S.C. 1502. Section 1.1502-76 also issued under 26 U.S.C. 1502. Section 1.1502-77 also issued under 26 U.S.C. 1502 and 6402(j). Section 1.1502-78 also issued under 26 U.S.C. 1502, 6402(j), and 6411(c). Section 1.1502-79 also issued under 26 U.S.C. 1502. Section 1.1502-80 also issued under 26 U.S.C. 1502. Section 1.1502-81T also issued under 26 U.S.C. 1502. Section 1.1502-90 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-91 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-92 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-93 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-94 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-95 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-96 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-98 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-99 also issued under 26 U.S.C. 382(m) and 26 U.S.C. 1502. Section 1.1502-100 also issued under 26 U.S.C. 1502. Sections 1.1503(d)-1 through 8 also issued under 26 U.S.C. 953(d), 1502, 1503(d) and (d)(2)(B), (d)(3), and (d)(4), and 7701. Section 1.1503-2T also issued under 26 U.S.C. 1503(d). Section 1.1504-3 also issued under 26 U.S.C. 1400Z-2(e)(4) and 1504(a)(5). Section 1.1504-4 also issued under 26 U.S.C. 1504(a)(5). Section 1.1502-77A also issued under 26 U.S.C. 1502 and 6402(j). Section 1.1502-77B also issued under 26 U.S.C. 1502 and 6402(j). Section 1.1561-2 also issued under 26 U.S.C. 1561. Section 1.5000A-3 also issued under 26 U.S.C. 5000A(e)(4). Section 1.5000C-1 is also issued under 26 U.S.C. 5000C Section 1.5000C-2 is also issued under 26 U.S.C. 5000C Section 1.5000C-3 is also issued under 26 U.S.C. 5000C Section 1.5000C-4 is also issued under 26 U.S.C. 5000C Section 1.5000C-5 is also issued under 26 U.S.C. 5000C Section 1.5000C-6 is also issued under 26 U.S.C. 5000C Section 1.6011-4T also issued under 26 U.S.C. 6001 and 6011(a). Section 1.6011-4T also issued under 26 U.S.C. 6011. Section 1.6011-6 also issued under 26 U.S.C. 6011(a). Section 1.6011-7 also issued under 26 U.S.C. 6011(e). Section 1.6011-9 also issued under 26 U.S.C. 6001 and 6011. Section 1.6011-10 also issued under 26 U.S.C. 6001 and 6011. Section 1.6011-11 also issued under 26 U.S.C. 6001 and 6011. Section 1.6011-15 also issued under 26 U.S.C. 6001 and 26 U.S.C. 6011. Section 1.6011-18 also issued under 26 U.S.C. 6001 and 26 U.S.C. 6011. Section 1.6012-2 is also issued under the authority of 26 U.S.C. 6011 and 6012. Section 1.6013-6 also issued under 26 U.S.C. 7701(b)(11). Section 1.6015-1 also issued under 26 U.S.C. 6015(h). Section 1.6015-2 also issued under 26 U.S.C. 6015(h). Section 1.6015-3 also issued under 26 U.S.C. 6015(h). Section 1.6015-4 also issued under 26 U.S.C. 6015(h). Section 1.6015-5 also issued under 26 U.S.C. 6015(h). Section 1.6015-6 also issued under 26 U.S.C. 6015(h). Section 1.6015-7 also issued under 26 U.S.C. 6015(h). Section 1.6015-8 also issued under 26 U.S.C. 6015(h). Section 1.6015-9 also issued under 26 U.S.C. 6015(h). Section 1.6031(a)-1 also issued under section 404 of the Tax Equity and Fiscal Responsibility Act of 1982 (Public Law 97-248; 96 Stat. 324, 669) (TEFRA). Section 1.6033-4 also issued under 26 U.S.C. 6033. Section 1.6033-6 also issued under 26 U.S.C. 6033(i)(1). Section 1.6035-1 also issued under 26 U.S.C. 6035. Section 1.6035-2 also issued under 26 U.S.C. 6035(b). Section 1.6035-2T also issued under 26 U.S.C. 6035. Section 1.6037-2 also issued under 26 U.S.C. 6037. Section 1.6038-2 also issued under 26 U.S.C. 6038. Section 1.6038-2T also issued under 26 U.S.C. 6038(d). Section 1.6038-3 also issued under 26 U.S.C. 6038. Section 1.6038-4 also issued under 26 U.S.C. 6001, 6011, 6012, 6031, and 6038. Section 1.6038-5 also issued under 26 U.S.C. 6038. Section 1.6038A-1 also issued under 26 U.S.C. 6001. Section 1.6038A-2 also issued under 26 U.S.C. 6038A and 6038C. Section 1.6038A-3 also issued under 26 U.S.C. 6038A and 7701(l). Section 1.6038A-4 also issued under 26 U.S.C. 6038A. Section 1.6038A-5 also issued under 26 U.S.C. 6038A. Section 1.6038A-6 also issued under 26 U.S.C. 6038A. Section 1.6038A-7 also issued under 26 U.S.C. 6038A. Section 1.6038B-1 also issued under 26 U.S.C. 6038B. Section 1.6038B-1T also issued under 26 U.S.C 6038B. Section 1.6038B-2 also issued under 26 U.S.C. 6038B. Section 1.6038B-2T also issued under 26 U.S.C. 6038B. Section 1.6038D-0 also issued under 26 U.S.C. 6038D. Section 1.6038D-1 also issued under 26 U.S.C. 6038D. Section 1.6038D-2 also issued under 26 U.S.C. 6038D. Section 1.6038D-3 also issued under 26 U.S.C. 6038D. Section 1.6038D-4 also issued under 26 U.S.C. 6038D. Section 1.6038D-5 also issued under 26 U.S.C. 6038D. Section 1.6038D-6 also issued under 26 U.S.C. 6038D. Section 1.6038D-7 also issued under 26 U.S.C. 6038D. Section 1.6038D-8 also issued under 26 U.S.C. 6038D. Section 1.6039I-1 also issued under 26 U.S.C. 6039I. Section 1.6041-1 also issued under 26 U.S.C. 6041(a). Section 1.6041-2 also issued under 26 U.S.C. 6041(d). Section 1.6041-3 also issued under 26 U.S.C. 62 and 6041(a). Section 1.6042-3 also issued under 26 U.S.C. 6045. Section 1.6043-4 also issued under 26 U.S.C. 6043(c). Section 1.6045-1 also issued under 26 U.S.C. 6045. Section 1.6045-1 also issued under 26 U.S.C. 6045(a). Section 1.6045-1T also issued under 26 U.S.C. 6045(g). Section 1.6045-2 also issued under 26 U.S.C. 6045. Section 1.6045-3 also issued under 26 U.S.C. 6045. Section 1.6045-4 also issued under 26 U.S.C. 6045. Section 1.6045A-1 also issued under 26 U.S.C. 6045A(a), (b), (c). Section 1.6045B-1 also issued under 26 U.S.C. 6045B(a), (c), (e). Section 1.6046-1 also issued 26 U.S.C. 6046(b). Section 1.6046A-1 also issued under 26 U.S.C. 6046A. Section 1.6047-2 is also issued under 26 U.S.C. 6047(d). Section 1.6049-4 also issued under 26 U.S.C. 6049 (a), (b), and (d). Section 1.6049-5 also issued under 26 U.S.C. 6049 (a), (b), and (d). Section 1.6049-5T also issued under 26 U.S.C. 6049. Section 1.6049-6 also issued under 6049(a), (b), and (d). Section 1.6049-7 also issued under 26 U.S.C. 860G(e), 1275(c) and 26 U.S.C. 6049(d)(7)(D). Section 1.6049-9 also issued under 26 U.S.C. 6049(a). Section 1.6049-10 also issued under 26 U.S.C. 6049(a). Section 1.6050E-1 also issued under 26 U.S.C. 6050E. Section 1.6050H-1 also issued under 26 U.S.C. 6050H. Section 1.6050H-2 also issued under 26 U.S.C. 6050H. Section 1.6050H-3 also issued under 26 U.S.C. 6050H(h). Section 1.6050I-1 also issued under 26 U.S.C. 6050I. Section 1.6050I-2 also issued under 26 U.S.C. 6050I. Section 1.6050K-1 also issued under 26 U.S.C. 6050K(a). Section 1.6050M-1 also issued under 26 U.S.C. 6050M. Section 1.6050P-1 also issued under 26 U.S.C. 6050P. Section 1.6050P-2 also issued under 26 U.S.C. 6050P. Section 1.6050S-1 also issued under 26 U.S.C. 6050S(g). Section 1.6050S-2 also issued under 26 U.S.C. 6050S(g). Section 1.6050S-3 also issued under 26 U.S.C. 6050S(g). Section 1.6050S-4 also issued under 26 U.S.C. 6050S(g). Section 1.6050X-1 also issued under 26 U.S.C. 6050X(a), (b). Section 1.6050Y-2 also issued under 26 U.S.C. 6050Y(a). Section 1.6050Y-3 also issued under 26 U.S.C. 6050Y(b). Section 1.6050Y-4 also issued under 26 U.S.C. 6050Y(c). Sections 1.6055-1 and 1.6055-2 also issued under 26 U.S.C. 6055. Section 1.6060-1 also issued under 26 U.S.C. 6060(a). Section 1.6061-2T also issued under 26 U.S.C. 6061. Section 1.6065-2T also issued under 26 U.S.C. 6065. Section 1.6081-1 also issued under 26 U.S.C. 6081. Section 1.6081-2 also issued under 26 U.S.C. 6081. Section 1.6081-2T also issued under 26 U.S.C. 6081. Section 1.6081-3 also issued under 26 U.S.C. 6081. Section 1.6081-4 also issued under 26 U.S.C. 6081. Section 1.6081-5 also issued under 26 U.S.C. 6081. Section 1.6081-6 also issued under 26 U.S.C. 6081. Section 1.6081-6T also issued under 26 U.S.C. 6081. Section 1.6081-7 also issued under 26 U.S.C. 6081. Section 1.6081-8 also issued under 26 U.S.C. 6081(a). Section 1.6081-9 also issued under 26 U.S.C. 6081(a). Section 1.6081-10 also issued under 26 U.S.C. 6081. Section 1.6081-11 also issued under 26 U.S.C. 6081. Section 1.6109-2 also issued under 26 U.S.C. 6109(a). Sections 1.6302-1, 1.6302-2, 1.6302-3 and 1.6302-4 also issued under 26 U.S.C. 6302(h). Section 1.6411-4 also issued under 26 U.S.C. 6402(i) and 6411(c). Section 1.6417-0 also issued under 26 U.S.C. 6417(h). Section 1.6417-1 also issued under 26 U.S.C. 6417(h). Section 1.6417-2 also issued under 26 U.S.C. 6417(h). Section 1.6417-3 also issued under 26 U.S.C. 6417(h). Section 1.6417-4 also issued under 26 U.S.C. 6417(h). Section 1.6417-5 also issued under 26 U.S.C. 6417(h). Section 1.6417-6 also issued under 26 U.S.C. 6417(h). Section 1.6418-1 also issued under 26 U.S.C. 6418(g) and (h). Section 1.6418-2 also issued under 26 U.S.C. 6418(g) and (h). Section 1.6418-3 also issued under 26 U.S.C. 6418(g) and (h). Section 1.6418-4 also issued under 26 U.S.C. 6418(g) and (h). Section 1.6418-5 also issued under 26 U.S.C. 48(a)(10)(C) and 6418(g) and (h). Section 1.6418-4T also issued under 26 U.S.C. 6418(g)(1) and (h). Section 1.6654-2 also issued under 26 U.S.C. 6654(n). Section 1.6655-5 also issued under 26 U.S.C. 6655(i)(2). Section 1.6662-6 also issued under 26 U.S.C. 6662. Section 1.6695-1 also issued under 26 U.S.C. 6060(b) and 6695(b). Section 1.6695-1 also issued under 26 U.S.C. 6695(b). Section 1.6695-2 also issued under 26 U.S.C. 6695(g). Section 1.6695-2T also issued under 26 U.S.C. 6695(g). Section 1.6851-2 also issued under 26 U.S.C 6851(d). Section 1.7520-1 also issued under 26 U.S.C. 7520(c)(2). Section 1.7520-1T also issued under 26 U.S.C. 7520(c)(2). Section 1.7520-2 also issued under 26 U.S.C. 7520(c)(2). Section 1.7520-3 also issued under 26 U.S.C. 7520(c)(2). Section 1.7520-4 also issued under 26 U.S.C. 7520(c)(2). Section 1.7701(l)-1 also issued under 26 U.S.C. 7701(l). Section 1.7701(l)-3 also issued under 26 U.S.C. 7701(l). Section 1.7701(l)-4 also issued under 26 U.S.C. 7701(l) and 954(c)(6)(A). Section 1.7702-2 also issued under 26 U.S.C. 7702(k). Section 1.7872-5(b)(17) also issued under 26 U.S.C. 7872. Section 1.7872-5T also issued under 26 U.S.C. 7872. Section 1.7872-15 also issued under 26 U.S.C. 1275 and 7872. Section 1.7874-1 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-1T also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-2 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-3 is also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-4 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-4T also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-5 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-5T also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-6 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-7 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-8 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-9 also issued under 26 U.S.C. 7874(c)(6) and (g). Section 1.7874-10 also issued under 26 U.S.C. 7874(c)(4) and (g). Section 1.7874-11 also issued under 26 U.S.C. 7874(g). Section 1.7874-12 also issued under 26 U.S.C. 7874(g).
Source
Source: T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 21, 1960; T.D. 9989, 89 FR 17606, Mar. 11, 2024, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 21, 1960, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11402, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, T.D. 9381, 73 FR 8604, Feb. 15, 2008, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11607, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11737, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11814, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.
Source
Source: T.D. 6500, 25 FR 11910, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.
Source
Source: Sections 1.1401-1 through 1.1403-1 contained in T.D. 6691, 28 FR 12796, Dec. 3, 1963, unless otherwise noted.
Source
Source: Sections 1.1401-1 through 1.1403-1 contained in T.D. 6691, 28 FR 12796, Dec. 3, 1963, unless otherwise noted. RELATED RULES
Amendments
[T.D. 9169, 69 FR 78154, Dec. 29, 2004]
Amendments
[T.D. 6795, 30 FR 938, Jan. 29, 1965]