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Federal law — U.S. Code and appendices · legal_authorities
For special provisions relating to foreign educational, charitable, and other exempt organizations, see sections 512(a) and 4948.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 878
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Source file: Laws/federal/codes/united-states-code/title-26/section-878-foreign-educational-charitable-and-certain-other-exempt-organizations--a4902588c9.md
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Source location: Title 26, Chapter 1, § 878; chapter-001-normal-taxes-and-surtaxes.md
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Tax-exempt foundations** There is hereby imposed on each private foundation which is exempt from taxation under section 501(a) for the taxable year, with respect to the carrying on of its activities, a tax equal to 1.39 percent of the net investment income of such foundation for the taxable year. **(b) Taxable foundations** There is hereby imposed on each private foundation which is not exempt from taxation under section 501(a) for the taxable year, with respect to the carrying on of its activities, a tax equal to— (1) the amount (if any) by which the sum of (A) the tax imposed under subsection (a) (computed as if such subsection applied to such private foundation for the taxable year), plus (B) the amount of the tax which would have been imposed under section 511 for the taxable year if such private foundation had been exempt from taxation under section 501(a), exceeds (2) the tax imposed under subtitle A on such private foundation for the taxable year. **(c) Net investment income defined** (1) **In general** — For purposes of subsection (a), the net investment income is the amount by which (A) the sum of the gross investment income and the capital gain net income exceeds (B) the deductions allowed by paragraph (3). Except to the extent inconsistent with the provisions of this section, net investment income shall be determined under the principles of subtitle A. (2) **Gross investment income** — For purposes of paragraph (1), the term “gross investment income” means the gross amount of income from interest, dividends, rents, payments with respect to securities loans (as defined in section 512(a)(5)), and royalties, but not including any such income to the extent included in computing the tax imposed by section 511. Such term shall also include income from s
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 4940
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Treatment of expatriates** (1) **In general** — Every nonresident alien individual to whom this section applies and who, within the 10-year period immediately preceding the close of the taxable year, lost United States citizenship shall be taxable for such taxable year in the manner provided in subsection (b) if the tax imposed pursuant to such subsection (after any reduction in such tax under the last sentence of such subsection) exceeds the tax which, without regard to this section, is imposed pursuant to section 871. (2) **Individuals subject to this section** — This section shall apply to any individual if— (A) the average annual net income tax (as defined in section 38(c)(1)) of such individual for the period of 5 taxable years ending before the date of the loss of United States citizenship is greater than $124,000, (B) the net worth of the individual as of such date is $2,000,000 or more, or (C) such individual fails to certify under penalty of perjury that he has met the requirements of this title for the 5 preceding taxable years or fails to submit such evidence of such compliance as the Secretary may require. In the case of the loss of United States citizenship in any calendar year after 2004, such $124,000 amount shall be increased by an amount equal to such dollar amount multiplied by the cost-of-living adjustment determined under section 1(f)(3) for such calendar year by substituting “2003” for “1992” in subparagraph (B) thereof. Any increase under the preceding sentence shall be rounded to the nearest multiple of $1,000. **(b) Alternative tax** A nonresident alien individual described in subsection (a) shall be taxable for the taxable year as provided in section 1 or 55, except that— (1) the gross income shall include only the gross inc
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 877
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Federal law — U.S. Code and appendices · legal_authorities
Page 2078 TITLE 26—INTERNAL REVENUE CODE § 878 Subparagraph (A) or (B) shall not apply to any individual unless the renunciation or vol- untary relinquishment is subsequently ap- proved by the issuance to the individual of a certificate of loss of nationality by the United States Department of State. (5) Long-term resident The term ‘‘long-term resident’’ has the meaning given to such term by section 877(e)(2). (6) Early distribution tax The term ‘‘early distribution tax’’ means any increase in tax imposed under section 72(t), 220(f)(4), 223(f)(4), 409A(a)(1)(B), 529(c)(6), 529A(c)(3), or 530(d)(4). (h) Other rules (1) Termination of deferrals, etc. In the case of any covered expatriate, not- withstanding any other provision of this title— (A) any time period for acquiring property which would result in the reduction in the amount of gain recognized with respect to property disposed of by the taxpayer shall terminate on the day before the expatriation date, and (B) any extension of time for payment of tax shall cease to apply on the day before the expatriation date and the unpaid portion of such tax shall be due and payable at the time and in the manner prescribed by the Secretary. (2) Step-up in basis Solely for purposes of determining any tax imposed by reason of subsection (a), property which was held by an individual on the date the individual first became a resident of the United States (within the meaning of section 7701(b)) shall be treated as having a basis on such date of not less than the fair market value of such property on such date. The pre- ceding sentence shall not apply if the indi- vidual elects not to have such sentence apply. Such an election, once made, shall be irrev- ocable. (3) Coordination with section 684 If
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 878
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