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TITLE 26 - INTERNAL REVENUE
CHAPTER I - INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
SUBCHAPTER A - INCOME TAX
PART 1 - INCOME TAXES
1.6046 - 1T - Returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock (temporary).
(a) through (f)(2) [Reserved] For further guidance, see 1.60461(a) through (f)(2).
(f)(3) U.S. person(i) In general. For purposes of section 6046 and this section, the term United States person has the meaning assigned to it by section 7701(a)(30), except as provided in paragraphs (f)(3) (ii) and (iii) of this section.
(ii) Special rule for individuals residing in certain possessions. With respect to individuals who are bona fide residents of Puerto Rico or any section 931 possession, as defined in 1.9311T(c)(1), the term United States person has the meaning assigned to it by 1.9573T.
(iii) Special rule for certain nonresident aliens. An individual for whom an election under section 6013(g) or (h) is in effect shall, subject to the exceptions contained in paragraph (f)(3)(ii) of this section, be considered a United States person for purposes of section 6046 and this section.
(f)(4) through (k) [Reserved] For further guidance, see 1.60461(f)(4) through (k).
(l) Effective date. This section shall apply for taxable years ending after October 22, 2004.
[T.D. 9194, 70 FR 18946, Apr. 11, 2005]
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