§905. Applicable rules — Inbound Citations
26 U.S.C. § 905
Cited by 12 provisions in release 119-102.
Citations to §905(c)
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(B) If the deduction under foreign tax law is adjusted, the taxpayer shall notify the Secretary of such adjustment on or before the date prescribed by regulations, and the Secretary shall redetermine the amount of the tax for the year or years affected. In any case described in the preceding sentence, rules similar to the rules of subsection (c) of section 905 shall apply.
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(F) For adjustments where tax is not paid within 2 years, see section 905(c).
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(4) providing for alternative adjustments to the application of section 905(c),
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(A) Recovery of foreign income taxes, see section 905(c).
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(d) The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
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(a) Except as otherwise provided in this section or section 905(c), no adjustment under this subchapter for any partnership taxable year may be made after the later of—(1) the date which is 3 years after the latest of—(A) the date on which the partnership return for such taxable year was filed,(B) the return due date for the taxable year, or(C) the date on which the partnership filed an administrative adjustment request with respect to such year under section 6227, or(2) in the case of any modification of an imputed underpayment under section 6225(c), the date that is 270 days (plus the number of days of any extension consented to by the Secretary under paragraph (7) thereof) after the date on which everything required to be submitted to the Secretary pursuant to such section is so submitted, or(3) in the case of any notice of a proposed partnership adjustment under section 6231(a)(2), the date that is 330 days (plus the number of days of any extension consented to by the Secretary under section 6225(c)(7)) after the date of such notice.
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(2) For overpayment in case of adjustments to accrued foreign taxes, see section 905(c).
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(5) For special rules applicable in cases where the adjustment of certain taxes allowed as a credit against income taxes or estate taxes results in additional tax, see section 905(c) (relating to the foreign tax credit for income tax purposes) and section 2016 (relating to taxes of foreign countries, States, etc., claimed as credit against estate taxes).
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(1) Adjustments to accrued foreign taxes, see section 905(c).
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(b) For purposes of this section, the term “foreign tax redetermination” means any redetermination for which a notice is required under subsection (c) of section 905 or paragraph (2) of section 404A(g).
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(1) For bond as a condition precedent to the allowance of the credit for accrued foreign taxes, see section 905(c).