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26 U.S.C. § 482 — Allocation of income and deductions among taxpayers
Federal law — U.S. Code and appendices · legal_authorities
In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In the case of any transfer (or license) of intangible property (within the meaning of section 367(d)(4)), the income with respect to such transfer or license shall be commensurate with the income attributable to the intangible. For purposes of this section, the Secretary shall require the valuation of transfers of intangible property (including intangible property transferred with other property or services) on an aggregate basis or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, if the Secretary determines that such basis is the most reliable means of valuation of such transfers.
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Stable record: federal_law:legal_authorities:record_usc_25b2619e77252f223a53c0a3
Source file: Laws/federal/codes/united-states-code/title-26/section-482-allocation-of-income-and-deductions-among-taxpayers--30c8d5b830.md
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Source location: Title 26, Chapter 1, § 482; chapter-001-normal-taxes-and-surtaxes.md
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In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In the case of any transfer (or license) of intangible property (within the meaning of section 367(d)(4)), the income with respect to such transfer or license shall be commensurate with the income attributable to the intangible. For purposes of this section, the Secretary shall require the valuation of transfers of intangible property (including intangible property transferred with other property or services) on an aggregate basis or the valuation of such a transfer on the basis of the realistic alternatives to such a transfer, if the Secretary determines that such basis is the most reliable means of valuation of such transfers.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Amount constituting interest** For purposes of this title, in the case of any payment—
(1) under any contract for the sale or exchange of any property, and
(2) to which this section applies,
there shall be treated as interest that portion of the total unstated interest under such contract which, as determined in a manner consistent with the method of computing interest under section 1272(a), is properly allocable to such payment.
**(b) Total unstated interest** For purposes of this section, the term “total unstated interest” means, with respect to a contract for the sale or exchange of property, an amount equal to the excess of—
(1) the sum of the payments to which this section applies which are due under the contract, over
(2) the sum of the present values of such payments and the present values of any interest payments due under the contract.
For purposes of the preceding sentence, the present value of a payment shall be determined under the rules of section 1274(b)(2) using a discount rate equal to the applicable Federal rate determined under section 1274(d).
**(c) Payments to which subsection (a) applies**
(1) **In general** — Except as provided in subsection (d), this section shall apply to any payment on account of the sale or exchange of property which constitutes part or all of the sales price and which is due more than 6 months after the date of such sale or exchange under a contract—
(A) under which some or all of the payments are due more than 1 year after the date of such sale or exchange, and
(B) under which there is total unstated interest.
(2) **Treatment of other debt instruments** — For purposes of this section, a debt instrument of the purchaser which is given in consideration for the sale or exchange of property shall not be treate
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 483
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** For purposes of this title—
(1) **Retirement** — Amounts received by the holder on retirement of any debt instrument shall be considered as amounts received in exchange therefor.
(2) **Ordinary income on sale or exchange where intention to call before maturity**
(A) *In general* — If at the time of original issue there was an intention to call a debt instrument before maturity, any gain realized on the sale or exchange thereof which does not exceed an amount equal to—
(i) the original issue discount, reduced by
(ii) the portion of original issue discount previously includible in the gross income of any holder (without regard to section 1272(a)(7) (or the corresponding provisions of prior law)),
shall be treated as ordinary income.
(B) *Exceptions* — This paragraph shall not apply to—
(i) any tax-exempt obligation, or
(ii) any holder who has purchased the debt instrument at a premium.
(3) **Certain short-term Government obligations**
(A) *In general* — On the sale or exchange of any short-term Government obligation, any gain realized which does not exceed an amount equal to the ratable share of the acquisition discount shall be treated as ordinary income.
(B) *Short-term Government obligation* — For purposes of this paragraph, the term “short-term Government obligation” means any obligation of the United States or any of its possessions, or of a State or any political subdivision thereof, or of the District of Columbia, which has a fixed maturity date not more than 1 year from the date of issue. Such term does not include any tax-exempt obligation.
(C) *Acquisition discount* — For purposes of this paragraph, the term “acquisition discount” means the excess of the stated redemption price at maturity over the t
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 1271
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Allowance of credit**
(1) **In general** — In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter the amount of the qualified adoption expenses paid or incurred by the taxpayer.
(2) **Year credit allowed** — The credit under paragraph (1) with respect to any expense shall be allowed—
(A) in the case of any expense paid or incurred before the taxable year in which such adoption becomes final, for the taxable year following the taxable year during which such expense is paid or incurred, and
(B) in the case of an expense paid or incurred during or after the taxable year in which such adoption becomes final, for the taxable year in which such expense is paid or incurred.
(3) **$10,000 credit for adoption of child with special needs regardless of expenses** — In the case of an adoption of a child with special needs which becomes final during a taxable year, the taxpayer shall be treated as having paid during such year qualified adoption expenses with respect to such adoption in an amount equal to the excess (if any) of $10,000 over the aggregate qualified adoption expenses actually paid or incurred by the taxpayer with respect to such adoption during such taxable year and all prior taxable years.
(4) **Portion of credit refundable** — So much of the credit allowed under paragraph (1) as does not exceed $5,000 shall be treated as a credit allowed under subpart C and not as a credit allowed under this subpart.
**(b) Limitations**
(1) **Dollar limitation** — The aggregate amount of qualified adoption expenses which may be taken into account under subsection (a) for all taxable years with respect to the adoption of a child by the taxpayer shall not exceed $10,000.
(2) **Income limitation**
(A) *In general* —
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 23
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Transfers of property from the United States**
(1) **General rule** — If, in connection with any exchange described in section 332, 351, 354, 356, or 361, a United States person transfers property to a foreign corporation, such foreign corporation shall not, for purposes of determining the extent to which gain shall be recognized on such transfer, be considered to be a corporation.
(2) **Exception for certain stock or securities** — Except to the extent provided in regulations, paragraph (1) shall not apply to the transfer of stock or securities of a foreign corporation which is a party to the exchange or a party to the reorganization.
(3) **Special rule for transfer of partnership interests** — Except as provided in regulations prescribed by the Secretary, a transfer by a United States person of an interest in a partnership to a foreign corporation in an exchange described in paragraph (1) shall, for purposes of this subsection, be treated as a transfer to such corporation of such person’s pro rata share of the assets of the partnership.
(4) **Paragraph (2) not to apply to certain section 361 transactions** — Paragraph (2) shall not apply in the case of an exchange described in subsection (a) or (b) of section 361. Subject to such basis adjustments and such other conditions as shall be provided in regulations, the preceding sentence shall not apply if the transferor corporation is controlled (within the meaning of section 368(c)) by 5 or fewer domestic corporations. For purposes of the preceding sentence, all members of the same affiliated group (within the meaning of section 1504) shall be treated as 1 corporation.
(5) **Secretary may exempt certain transactions from application of this subsection** — Paragraph (1) shall not apply to the transfer of any pro
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 367
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Federal law — U.S. Code and appendices · legal_authorities
As used in this chapter, the following terms have the following meanings:
(1) A “digital audio copied recording” is a reproduction in a digital recording format of a digital musical recording, whether that reproduction is made directly from another digital musical recording or indirectly from a transmission.
(2) A “digital audio interface device” is any machine or device that is designed specifically to communicate digital audio information and related interface data to a digital audio recording device through a nonprofessional interface.
(3) A “digital audio recording device” is any machine or device of a type commonly distributed to individuals for use by individuals, whether or not included with or as part of some other machine or device, the digital recording function of which is designed or marketed for the primary purpose of, and that is capable of, making a digital audio copied recording for private use, except for—
(A) professional model products, and
(B) dictation machines, answering machines, and other audio recording equipment that is designed and marketed primarily for the creation of sound recordings resulting from the fixation of nonmusical sounds.
(4)
(A) A “digital audio recording medium” is any material object in a form commonly distributed for use by individuals, that is primarily marketed or most commonly used by consumers for the purpose of making digital audio copied recordings by use of a digital audio recording device.
(B) Such term does not include any material object—
(i) that embodies a sound recording at the time it is first distributed by the importer or manufacturer; or
(ii) that is primarily marketed and most commonly used by consumers either for the purpose of making copies of motion pictures or other audiovisual
Source: Supplied U.S. Code snapshot — release unconfirmed · 17 U.S.C. § 1001
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** The Secretary may not enter into any contract with a foreign incorporated entity which is treated as an inverted domestic corporation under subsection (b), or any subsidiary of such an entity.
**(b) Inverted domestic corporation** For purposes of this section, a foreign incorporated entity shall be treated as an inverted domestic corporation if, pursuant to a plan (or a series of related transactions)—
(1) the entity completes before, on, or after November 25, 2002, the direct or indirect acquisition of substantially all of the properties held directly or indirectly by a domestic corporation or substantially all of the properties constituting a trade or business of a domestic partnership;
(2) after the acquisition at least 80 percent of the stock (by vote or value) of the entity is held—
(A) in the case of an acquisition with respect to a domestic corporation, by former shareholders of the domestic corporation by reason of holding stock in the domestic corporation; or
(B) in the case of an acquisition with respect to a domestic partnership, by former partners of the domestic partnership by reason of holding a capital or profits interest in the domestic partnership; and
(3) the expanded affiliated group which after the acquisition includes the entity does not have substantial business activities in the foreign country in which or under the law of which the entity is created or organized when compared to the total business activities of such expanded affiliated group.
**(c) Definitions and special rules**
(1) **Rules for application of subsection (b)** — In applying subsection (b) for purposes of subsection (a), the following rules shall apply:
(A) *Certain stock disregarded* — There shall not be taken into account in determining ownershi
Source: Supplied U.S. Code snapshot — release unconfirmed · 6 U.S.C. § 415
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Federal law — U.S. Code and appendices · legal_authorities
Page 1657
TITLE 26—INTERNAL REVENUE CODE
§ 483
made within six months after Sept. 2, 1958. Claims for
refunds of overpayments of tax resulting from the elec-
tion were to be filed within one year after the date of
the election. Such an election was to be considered a
consent to an assessment of a deficiency resulting from
the election, where the assessment is made within one
year after the date of the election.
§ 482. Allocation of income and deductions
among taxpayers
In any case of two or more organizations,
trades, or businesses (whether or not incor-
porated, whether or not organized in the United
States, and whether or not affiliated) owned or
controlled directly or indirectly by the same in-
terests, the Secretary may distribute, appor-
tion, or allocate gross income, deductions, cred-
its, or allowances between or among such orga-
nizations, trades, or businesses, if he determines
that such distribution, apportionment, or allo-
cation is necessary in order to prevent evasion
of taxes or clearly to reflect the income of any
of such organizations, trades, or businesses. In
the case of any transfer (or license) of intangible
property
(within
the
meaning
of
section
367(d)(4)), the income with respect to such trans-
fer or license shall be commensurate with the
income attributable to the intangible. For pur-
poses of this section, the Secretary shall require
the valuation of transfers of intangible property
(including intangible property transferred with
other property or services) on an aggregate basis
or the valuation of such a transfer on the basis
of the realistic alternatives to such a transfer, if
the Secretary determines that such basis is the
most reliable means of valuation of such trans-
fers.
(Aug. 16, 1954, ch. 736, 68A Stat.
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 482
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