§67. 2-percent floor on miscellaneous itemized deductions — Inbound Citations
26 U.S.C. § 67
Cited by 6 provisions in release 119-102.
Citations to §67(b)
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(i) for any miscellaneous itemized deduction (as defined in section 67(b)), or
Citations to §67(c)(2)(B)
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(5) Except to the extent provided in regulations prescribed by the Secretary, subsection (a) shall apply to any distribution in redemption of stock of a publicly offered regulated investment company (within the meaning of section 67(c)(2)(B)) if—(A) such redemption is upon the demand of the stockholder, and
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(1) Except in the case of a publicly offered regulated investment company (as defined in section 67(c)(2)(B)) or a publicly offered REIT, the amount of any distribution shall not be considered as a dividend for purposes of computing the dividends paid deduction, unless such distribution is pro rata, with no preference to any share of stock as compared with other shares of the same class, and with no preference to one class of stock as compared with another class except to the extent that the former is entitled (without reference to waivers of their rights by shareholders) to such preference. In the case of a distribution by a regulated investment company (other than a publicly offered regulated investment company (as so defined)) to a shareholder who made an initial investment of at least $10,000,000 in such company, such distribution shall not be treated as not being pro rata or as being preferential solely by reason of an increase in the distribution by reason of reductions in administrative expenses of the company.
Citations to §67(e)
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(II) by applying section 67(e) (without the reference to section 642(b)) for purposes of determining the adjusted gross income of the trust.
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(i) the adjusted gross income (as defined in section 67(e)) for such taxable year, over
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(iii) In the case of an estate or trust, adjusted gross income shall be determined as provided in section 67(e).