§1351. Treatment of recoveries of foreign expropriation losses — Inbound Citations
26 U.S.C. § 1351
Cited by 7 provisions in release 119-102.
Citations to 26 U.S.C. § 1351 as a whole
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(d) This section shall not apply to any recovery of a foreign expropriation loss to which section 1351 applies.
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(1) a corporation has a recovery of a foreign expropriation loss to which section 1351 applies, and
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(b) If a corporation has a recovery of a foreign expropriation loss to which section 1351 applies and if an election is not made under subsection (a), the Secretary may, upon finding that the payment of the tax attributable to such recovery at the time otherwise provided in this subtitle would result in undue hardship, extend the time for payment of such tax for a reasonable period or periods not in excess of 9 years from the date on which such tax is otherwise payable.
Citations to §1351(c)
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(2) the portion of the recovery received in money is less than 25 percent of the amount of such recovery (as defined in section 1351(c)) and is not greater than the tax attributable to such recovery,
Citations to §1351(d)(1)
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(H) section 1351(d)(1) (relating to recoveries of foreign expropriation losses),
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(1) the additional tax imposed by section 1351(d)(1) on such recovery, and
Citations to §1351(e)
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(2) the amount by which the tax imposed under subtitle A is increased by reason of the gain on such recovery which under section 1351(e) is considered as gain on the involuntary conversion of property.