(c)– 5 this section, an interest constructively owned by a person by reason of the ap- plication of paragraph (b) (1), (2), (4), (5), or (6) of this section shall.
and 416 and the regulations thereunder for rules relating to employees of trades or businesses which are under common control. See § (c)-5 for effective.
plan for all employers maintain- ing the plan. (4) Effective dates. Except as other- wise provided, section and this section . See § (c)– 5 for ef-. 2ARM the application of the credit for increasing research activities. In any case in which the Commissioner determines that the structure of one or. In addition, the final regulations provide rules for determining whether a 1.414(c)-5 is considered to derive rents and royalties in the active conduct of a trade or business for 1.414(c)-5 of determining foreign personal holding company income FPHCIas well as 1.414(c)-5 for determining whether a CFC holds United States property as a result of certain related party factoring transactions. Summary This document contains final and temporary regulations regarding withholding 1.414(c)-5 tax on certain U.