§6038. Information reporting with respect to certain foreign corporations and partnerships — Inbound Citations
26 U.S.C. § 6038
Cited by 5 provisions in release 119-102.
Citations to 26 U.S.C. § 6038 as a whole
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(1) For purposes of this chapter, section 6038, section 6046, and such other provisions as may be specified in regulations—(A) a qualified insurance branch of a controlled foreign corporation shall be treated as a separate foreign corporation created under the laws of the foreign country with respect to which such branch qualifies under paragraph (2), and(B) except as provided in regulations, any amount directly or indirectly transferred or credited from such branch to one or more other accounts of such controlled foreign corporation shall be treated as a dividend paid to such controlled foreign corporation.
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(A) In the case of any information which is required to be reported to the Secretary pursuant to an election under section 1295(b) or under section 1298(f), 6038, 6038A, 6038B, 6038D, 6046, 6046A, or 6048, the time for assessment of any tax imposed by this title with respect to any tax return, event, or period to which such information relates shall not expire before the date which is 3 years after the date on which the Secretary is furnished the information required to be reported under such section.
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(2) For purposes of this subsection, the term “undisclosed foreign financial asset” means, with respect to any taxable year, any asset with respect to which information was required to be provided under section 6038, 6038B, 6038D, 6046A, or 6048 for such taxable year but was not provided by the taxpayer as required under the provisions of those sections.
Citations to §6038(e)(2)
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(8) section 6038(e)(2) (relating to information with respect to certain foreign corporations).
Citations to §6038(e)(3)(C)
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(d) For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).