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- Revenue Ruling 2004-47 - Section 265(a)(2); Expenses And Interest Relating To Taxexempt Income
Get Revenue Ruling 2004-47 - Section 265(a)(2); Expenses And Interest Relating To Taxexempt Income
Such allocations are not limited by 1.197 2(h)(12)(vii)(B). HOLDING If, pursuant to 1.704 1(b)(2)(iv)(f), a partnership revalues a section 197 intangible that was amortizable in the hands of the partnership, then the 197 anti-churning rules do not apply and the partnership may make reverse 704(c) allocations (including curative and remedial allocations) of amortization to take into account the built-in gain or loss from the revaluation of the intangible. If the revalued section 1.
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1970 FAQ
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(B) Limitation. The amount of tax-exempt obligations not taken into account by reason of subparagraph (A) shall not exceed 2 percent of the amount determined under paragraph (2)(B).
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tax-exempt interest income — interest income that is not subject to income tax. Tax-exempt interest income is earned from bonds issued by states, cities, or counties and the District of Columbia.
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265(b)Pro Rata Allocation of Interest Expense of Financial Institutions to Tax-Exempt Interest. In the case of a financial institution, no deduction shall be allowed for that portion of the taxpayer's interest expense which is allocable to tax-exempt interest. Such average adjusted bases for all assets of the taxpayer.
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42 U.S. Code § 265 - Suspension of entries and imports from designated places to prevent spread of communicable diseases.
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(i)For purposes of subparagraph (A), the term “qualified tax-exempt obligation” means a tax-exempt obligation— (I)which is issued after, by a qualified small issuer, (II)which is not a private activity bond (as defined in), and (III)which is designated by the issuer for purposes of this paragraph. (
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Section 265(a)(2) disallows a deduction for interest expense related to tax-exempt obligations. Section 265(b)(3) provides an exception to the rule that generally disallows the deduction for interest expense. Tax-exempt obligations must meet the requirements of a qualified tax- exempt bond for the exception to apply.
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tax-exempt interest income — interest income that is not subject to income tax. Tax-exempt interest income is earned from bonds issued by states, cities, or counties and the District of Columbia.
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265(b)Pro Rata Allocation of Interest Expense of Financial Institutions to Tax-Exempt Interest. In the case of a financial institution, no deduction shall be allowed for that portion of the taxpayer's interest expense which is allocable to tax-exempt interest.
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