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26 U.S.C. § 177 — Repealed. Pub. L. 99–514, title II, § 241(a), Oct. 22, 1986, 100 Stat. 2181]

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 177 — Repealed. Pub. L. 99–514, title II, § 241(a), Oct. 22, 1986, 100 Stat. 2181]

### Statutory Notes Section, added June 29, 1956, ch. 464, § 4(a), 70 Stat. 406; amended Oct. 4, 1976, Pub. L. 94–455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834, related to deductions for trademark and trade name expenditures. #### Effective Date of Repeal Pub. L. 99–514, title II, § 241(c), Oct. 22, 1986, 100 Stat. 2181, provided that: “(1) In general.—Except as provided in paragraph (2), the amendments made by this section [amending sections 312 and 1016 of this title and repealing this section] shall apply to expenditures paid or incurred after December 31, 1986. “(2) Transitional rule.—The amendments made by this section shall not apply to any expenditure incurred—“(A) pursuant to a binding contract entered into before March 2, 1986, or “(B) with respect to the development, protection, expansion, registration, or defense of a trademark or trade name commenced before March 2, 1986, but only if not less than the lesser of $1,000,000 or 5 percent of the aggregate cost of such development, protection, expansion, registration, or defense has been incurred or committed before such date. The preceding sentence shall not apply to any expenditure with respect to a trademark or trade name placed in service after December 31, 1987.”

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Source location: Title 26, Chapter 1, § 177; chapter-001-normal-taxes-and-surtaxes.md

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### Statutory Notes Section, added June 29, 1956, ch. 464, § 4(a), 70 Stat. 406; amended Oct. 4, 1976, Pub. L. 94–455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834, related to deductions for trademark and trade name expenditures. #### Effective Date of Repeal Pub. L. 99–514, title II, § 241(c), Oct. 22, 1986, 100 Stat. 2181, provided that: “(1) In general.—Except as provided in paragraph (2), the amendments made by this section [amending sections 312 and 1016 of this title and repealing this section] shall apply to expenditures paid or incurred after December 31, 1986. “(2) Transitional rule.—The amendments made by this section shall not apply to any expenditure incurred—“(A) pursuant to a binding contract entered into before March 2, 1986, or “(B) with respect to the development, protection, expansion, registration, or defense of a trademark or trade name commenced before March 2, 1986, but only if not less than the lesser of $1,000,000 or 5 percent of the aggregate cost of such development, protection, expansion, registration, or defense has been incurred or committed before such date. The preceding sentence shall not apply to any expenditure with respect to a trademark or trade name placed in service after December 31, 1987.”

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 1016 — Adjustments to basis

**(a) General rule** Proper adjustment in respect of the property shall in all cases be made— (1) for expenditures, receipts, losses, or other items, properly chargeable to capital account, but no such adjustment shall be made— (A) for— (i) taxes or other carrying charges described in section 266; or (ii) expenditures described in section 173 (relating to circulation expenditures), for which deductions have been taken by the taxpayer in determining taxable income for the taxable year or prior taxable years; or (B) for mortality, expense, or other reasonable charges incurred under an annuity or life insurance contract; (2) in respect of any period since February 28, 1913, for exhaustion, wear and tear, obsolescence, amortization, and depletion, to the extent of the amount— (A) allowed as deductions in computing taxable income under this subtitle or prior income tax laws, and (B) resulting (by reason of the deductions so allowed) in a reduction for any taxable year of the taxpayer’s taxes under this subtitle (other than chapter 2, relating to tax on self-employment income), or prior income, war-profits, or excess-profits tax laws, but not less than the amount allowable under this subtitle or prior income tax laws. Where no method has been adopted under section 167 (relating to depreciation deduction), the amount allowable shall be determined under the straight line method. Subparagraph (B) of this paragraph shall not apply in respect of any period since February 28, 1913, and before January 1, 1952, unless an election has been made under section 1020 (as in effect before the date of the enactment of the Tax Reform Act of 1976). Where for any taxable year before the taxable year 1932 the depletion allowance was based on discovery value or a pe

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 312 — Effect on earnings and profits

**(a) General rule** Except as otherwise provided in this section, on the distribution of property by a corporation with respect to its stock, the earnings and profits of the corporation (to the extent thereof) shall be decreased by the sum of— (1) the amount of money, (2) the principal amount of the obligations of such corporation (or, in the case of obligations having original issue discount, the aggregate issue price of such obligations), and (3) the adjusted basis of the other property, so distributed. **(b) Distributions of appreciated property** On the distribution by a corporation, with respect to its stock, of any property (other than an obligation of such corporation) the fair market value of which exceeds the adjusted basis thereof— (1) the earnings and profits of the corporation shall be increased by the amount of such excess, and (2) subsection (a)(3) shall be applied by substituting “fair market value” for “adjusted basis”. For purposes of this subsection and subsection (a), the adjusted basis of any property is its adjusted basis as determined for purposes of computing earnings and profits. **(c) Adjustments for liabilities** In making the adjustments to the earnings and profits of a corporation under subsection (a) or (b), proper adjustment shall be made for— (1) the amount of any liability to which the property distributed is subject, and (2) the amount of any liability of the corporation assumed by a shareholder in connection with the distribution. **(d) Certain distributions of stock and securities** (1) **In general** — The distribution to a distributee by or on behalf of a corporation of its stock or securities, of stock or securities in another corporation, or of property, in a distribution to which this title applies, shall not be consid

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Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 177 — Untitled legal text

Page 895 TITLE 26—INTERNAL REVENUE CODE § 179 extent not compensated for) paid or incurred pursuant to an agreement entered into under section 3121(l) with respect to services performed by United States citizens employed by foreign subsidiary corporations. Any reimbursement of any amount previously allowed as a deduction under this section shall be included in gross in- come for the taxable year in which received. (Added Sept. 1, 1954, ch. 1206, title II, § 210(a), 68 Stat. 1096.) [§ 177. Repealed. Pub. L. 99–514, title II, § 241(a), Oct. 22, 1986, 100 Stat. 2181] Section, added June 29, 1956, ch. 464, § 4(a), 70 Stat. 406; amended Oct. 4, 1976, Pub. L. 94–455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834, related to deductions for trademark and trade name expenditures. Statutory Notes and Related Subsidiaries EFFECTIVE DATE OF REPEAL Pub. L. 99–514, title II, § 241(c), Oct. 22, 1986, 100 Stat. 2181, provided that: ‘‘(1) IN GENERAL.—Except as provided in paragraph (2), the amendments made by this section [amending sec- tions 312 and 1016 of this title and repealing this sec- tion] shall apply to expenditures paid or incurred after December 31, 1986. ‘‘(2) TRANSITIONAL RULE.—The amendments made by this section shall not apply to any expenditure in- curred— ‘‘(A) pursuant to a binding contract entered into before March 2, 1986, or ‘‘(B) with respect to the development, protection, expansion, registration, or defense of a trademark or trade name commenced before March 2, 1986, but only if not less than the lesser of $1,000,000 or 5 percent of the aggregate cost of such development, protection, expansion, registration, or defense has been incurred or committed before such date. The preceding sentence shall not apply to any expendi- ture with res

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