Internal Revenue Code

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Table of Contents IRC 11(a) - Tax imposed 2 IRC 7701(a)(3) - Definitions 2 IRC 7701(a)(4) 2 IRC 7701(a)(5) 2 Reg 301-7701-3(a); 301-7701-3(b)(1); 301-7701-3(c) 2 Section 301.7701-3(a) 2 Section 301.7701-3(c) 3 IRC 243 - Dividends received by corporations 3 (a) General rule 3 (b) Qualifying dividends 3 (C) Election 5 (d) Special rules for certain distributions 5 (e) Certain dividends from foreign corporations 6 IRC 246(b), 246(c) - Rules applying to deductions for dividends received 6 (b) Limitation on aggregate amount of deductions 6 (c) Exclusion of certain dividends 6 IRC 248 - Organizational expenditures 8 (a) Election to deduct 8 (b) Organizational expenditures defined 8 (c) Time for and scope of…show more content…
(2) Affiliated group
For purposes of this subsection:
(A) In general
The term “affiliated group” has the meaning given such term by section 1504 (a), except that for such purposes sections 1504 (b)(2), 1504 (b)(4), and 1504 (c) shall not apply.
(B) Group must be consistent in foreign tax treatment
The requirements of paragraph (1)(A) shall not be treated as being met with respect to any dividend received by a corporation if, for any taxable year which includes the day on which such dividend is received—
(i) 1 or more members of the affiliated group referred to in paragraph (1)(A) choose to any extent to take the benefits of section 901, and
(ii) 1 or more other members of such group claim to any extent a deduction for taxes otherwise creditable under section 901.
(3) Special rule for groups which include life insurance companies
(A) In general
In the case of an affiliated group which includes 1 or more insurance companies under section 801, no dividend by any member
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