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e-CFR data is current as of September 28, 2020

Title 26Chapter ISubchapter APart 1 → §1.280h-0t


Title 26: Internal Revenue
PART 1—INCOME TAXES (CONTINUED)


§1.280H-0T   Table of contents (temporary).

This section lists the captions that appear in the temporary regulations under section 280H.

§1.280H-1T Limitation on certain amounts paid to employee-owners by personal service corporations electing alternative taxable years (temporary).

(a) Introduction.

(b) Limitations on certain deductions of a personal service corporation.

(1) In general.

(2) Carryover of nondeductible amounts.

(3) Disallowance inapplicable for certain purposes.

(4) Definition of applicable amount.

(i) In general.

(ii) Special rule for certain indirect payments.

(iii) Examples.

(c) Minimum distribution requirement.

(1) Determination of whether requirement satisfied.

(i) In general.

(ii) Employee-owner defined.

(2) Preceding year test.

(i) In general.

(ii) Example.

(3) 3-year average test.

(i) In general.

(ii) Applicable percentage.

(iii) Adjusted taxable income.

(A) In general.

(B) Determination of adjusted taxable income for the deferral period of the applicable election year.

(C) NOL carryovers.

(D) Examples.

(d) Maximum deductible amount.

(1) In general.

(2) Example.

(e) Special rules and definition.

(1) Newly organized personal service corporations.

(2) Existing corporations that become personal service corporations.

(3) Disallowance of NOL carryback.

(4) Deferral period.

(5) Examples.

(f) Effective date.

[T.D. 8205, 53 FR 19711, May 27, 1988]

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