§6038A. Information with respect to certain foreign-owned corporations — Inbound Citations
26 U.S.C. § 6038A
Cited by 11 provisions in release 119-102.
Citations to 26 U.S.C. § 6038A as a whole
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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.
Citations to §6038A(b)
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(1) the information described in section 6038A(b), and
Citations to §6038A(b)(2)
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(B) No payments shall be treated as qualified derivative payments under subparagraph (A) for any taxable year unless the taxpayer includes in the information required to be reported under section 6038A(b)(2) with respect to such taxable year such information as is necessary to identify the payments to be so treated and such other information as the Secretary determines necessary to carry out the provisions of this subsection.
Citations to §6038A(c)
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(e) For purposes of this section, the terms “related party”, “foreign person”, and “records” have the respective meanings given to such terms by section 6038A(c).
Citations to §6038A(c)(3)
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(f) For purposes of this section, the term “foreign person” has the meaning given such term by section 6038A(c)(3).
Citations to §6038A(d)
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(c) The provisions of subsection (d) of section 6038A shall apply to—(1) any failure to furnish (within the time prescribed by regulations) any information described in subsection (b), and(2) any failure to maintain (or cause another to maintain) records as required by subsection (a),in the same manner as if such failure were a failure to comply with the provisions of section 6038A.
Citations to §6038A(e)(2)
Citations to §6038A(e)(4)
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(B) such summons is not quashed in a proceeding begun under paragraph (4) of section 6038A(e) (as made applicable by paragraph (4) of this subsection) and is not determined to be invalid in a proceeding begun under section 7604(b) to enforce such summons, and
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(4) The provisions of section 6038A(e)(4) shall apply with respect to any summons referred to in paragraph (2)(A); except that subparagraph (D) of such section shall be applied by substituting “transaction or item” for “transaction”.
Citations to §6038A(e)(4)(D)
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(4) The provisions of section 6038A(e)(4) shall apply with respect to any summons referred to in paragraph (2)(A); except that subparagraph (D) of such section shall be applied by substituting “transaction or item” for “transaction”.