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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   n 482. The 1993 notice of proposed rulemaking gave the following explanation of section 1.482-1T(f)(2), Proposed In come Tax Regs., 58 Fed. Reg. 5312: Section 1.482-1T(f)(2) provides guidance on the extent to which foreign legal restrictions on payments between controlled taxpayers will be respected for purposes of sec…
2. Treas. Reg. § 1.411(d)-5 — [Reserved]
   IRCRegulationsMar 14, 2019related by meaning
   [Reserved]
3. Treas. Reg. § 1.410(b)-1 — [Reserved]
   IRCRegulationsMar 14, 2019related by meaning
   [Reserved]
4. Treas. Reg. § 1.411(a)-9 — [Reserved]
   IRCRegulationsMar 14, 2019related by meaning
   [Reserved]
5. Treas. Reg. § 54.4975-15(a) — Other transitional rules.
   IRCRegulationsDec 30, 2016related by meaning
   (a) (a) -(c) [Reserved]
6. Treas. Reg. § 54.9816-3(b) — Definitions.
   IRCRegulationsAug 3, 2026related by meaning
   (b) (b) For further guidance, see 29 CFR 2590.716-3.
7. Treas. Reg. § 54.4980H-6(a) — Administration and procedure.
   IRCRegulationsDec 30, 2016related by meaning
   (a) (a) In general. [Reserved]
8. Treas. Reg. § 1.411(a)-4T(b) — Forfeitures, suspensions, etc. (temporary).
   IRCRegulationsSep 9, 2016related by meaning
   (b) (b) [Reserved]
9. Treas. Reg. § 54.4975-7(a) — Other statutory exemptions.
   IRCRegulationsDec 30, 2016related by meaning
   (a) (a) [Reserved]
10. Treas. Reg. § 1.72-2(ii)(3) — Applicability of section.
    IRCRegulationsJul 26, 2016related by meaning
    (ii)(3) (3)
11. Treas. Reg. § 54.9812-2(f) — Nonquantitative treatment limitation comparative analysis requirements.
    IRCRegulationsNov 22, 2024related by meaning
    (f) (f) Rule of construction. Nothing in this section or § 54.9812-1 shall be construed to prevent the Secretary from acting within the scope of existing authorities to address violations of § 54.9812-1 or this section.
12. Treas. Reg. § 54.6011-1T(b) — General requirement of return, statement, or list (temporary).
    IRCRegulationsDec 30, 2016related by meaning
    (b) (b) [Reserved]
13. Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of…
    IRCNoticesMay 18, 2026related by meaning
    ic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F…
14. Treas. Reg. § 1.402(e)-1 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
15. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …e methods.” Id. para. (g)(1). “Each method must be applied in accordance with the provisions of § 1.482-1, including the best method rule of § 1.482-1(c), the comparability analysis of § 1.482-1(d), and the arm’s length range of § 1.482-1(e), except as those provisions are modified in this paragraph (g).” Temp. Treas. …
16. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    ction and shall not affect the remainder thereof or the application of the provision to persons not similarly situated or to dissimilar circumstances. (2) The provisions of paragraphs (b)(1), (c)(2)(ii), (c)(4), (d)(2), and (g)(1) of this section are intended to be severable from one another, from any grant of forbeara…
17. Treas. Reg. § 1.410(a)-3T(a) — Minimum age and service conditions (temporary).
    IRCRegulationsSep 9, 2016related by meaning
    (a) (a) [Reserved]
18. Treas. Reg. § 1.404(e)-1 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
19. Treas. Reg. § 54.9801-1T(a) — Basis and scope (temporary).
    IRCRegulationsSep 13, 2021related by meaning
    (a) (a) Statutory basis. This section and §§ 54.9801-2 through 54.9801-6, 54.9802-1, 54.9802-2, 54.9802-3T, 54.9802-4, 54.9811-1, 54.9812-1, 54.9815-1251, 54.9815-2704, 54.9815-2705, 54.9815-2708, 54.9815-2711, 54.9815-2712, 54.9815-2713, 54.9815-2713A, 54.9815-2714, 54.9815-2715, 54.9815-2715A1, 54.9815-2715A2, 54.981…
20. Notice 2004-8 — Roth IRAs; abuses; listed transactions. This notice describes certain transactions that are being entered into by individuals, their Roth IRAs, and their busin…
    IRCNoticesJan 26, 2004
    … 370 F.2d 713 (1st Cir. 1966). Depending on the facts of the specific case, the Service may apply § 482 to allocate income from the Roth IRA Corporation to the Taxpayer, Business, or other entities under the control of the Taxpayer. Section 482 provides the Secretary with authority to allocate gross income, deductions,…