Apr. 1, 2002 Title 26 Internal Revenue Parts 500 to 599 Revised as of April 1, 2020 Containing a codification of documents of general applicability and future effect As of April 1, 2020

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 Table of Contents Page Explanation v Title 26: Chapter I—Internal Revenue Service, Department of the Treasury (Continued) 3 Finding Aids: Table of CFR Titles and Chapters 49 Alphabetical List of Agencies Appearing in the CFR 69 Table of OMB Control Numbers 79 List of CFR Sections Affected 97

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        THIS TITLE

Title 26— Internal Revenue is composed of twenty-two volumes. The contents of these volumes represent all current regulations issued by the Internal Revenue Service, Department of the Treasury, as of April 1, 2019. The first fifteen volumes comprise part 1 (Subchapter A—Income Tax) and are arranged by sections as follows: §§ 1.0-1.60; §§ 1.61-1.139; §§ 1.140-1.169; §§ 1.170-1.300; §§ 1.301-1.400; §§ 1.401-1.409; §§ 1.410-1.440; §§ 1.441-1.500; §§ 1.501-1.640; §§ 1.641-1.850; §§ 1.851-1.907; §§ 1.908-1.1000; §§ 1.1001-1.1400; §§ 1.1401-1.1550; and § 1.1551 to end of part 1. The sixteenth volume containing parts 2-29, includes the remainder of subchapter A and all of Subchapter B—Estate and Gift Taxes. The last six volumes contain parts 30-39 (Subchapter C—Employment Taxes and Collection of Income Tax at Source); parts 40-49; parts 50-299 (Subchapter D—Miscellaneous Excise Taxes); parts 300-499 (Subchapter F—Procedure and Administration); parts 500-599 (Subchapter G—Regulations under Tax Conventions); and part 600 to end (Subchapter H—Internal Revenue Practice).

The OMB control numbers for title 26 appear in § 602.101 of this chapter. For the convenience of the user, § 602.101 appears in the Finding Aids section of the volumes containing parts 1 to 599.

For this volume, Robert J. Sheehan, III was Chief Editor. The Code of Federal Regulations publication program is under the direction of John Hyrum Martinez, assisted by Stephen J. Frattini.

 <LRH>26 CFR Ch. I (4-1-20 Edition)</LRH> <RRH>Internal Revenue Service, Treasury</RRH> <CFRTITLE> <TITLEHD> <PRTPAGE P="1"/> <HD SOURCE="HED">Title 26—Internal Revenue</HD> <P>(This book contains Parts 500 to 599)</P> </TITLEHD> <CFRTOC> <PTHD>Part</PTHD> <CHAPTI> <SUBJECT> <E T="04">chapter i</E> —Internal Revenue Service, Department of the Treasury (Continued) </SUBJECT> <PG>502</PG> </CHAPTI> </CFRTOC> </CFRTITLE> <CHAPTER> <TOC> <TOCHD> <PRTPAGE P="3"/> <HD SOURCE="HED">CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED)</HD> </TOCHD> <EDNOTE> <HD SOURCE="HED">Editorial Note:</HD> <P>IRS published a document at 45 FR 6088, Jan. 25, 1980, deleting statutory sections from their regulations. In Chapter I cross references to the deleted material have been changed to the corresponding sections of the IRS Code of 1954 or to the appropriate regulations sections. When either such change produced a redundancy, the cross reference has been deleted. For further explanation, see 45 FR 20795, Mar. 31, 1980.</P> </EDNOTE> <SUBCHAP> <HD SOURCE="HED">SUBCHAPTER G—REGULATIONS UNDER TAX CONVENTIONS</HD> </SUBCHAP> <PTHD>Part</PTHD> <PGHD>Page</PGHD> <CHAPTI> <PT>500-507</PT> <RESERVED>[Reserved]</RESERVED> <PT>509</PT> <SUBJECT>Switzerland</SUBJECT> <PG>5</PG> <PT>510-512</PT> <RESERVED>[Reserved]</RESERVED> <PT>513</PT> <SUBJECT>Ireland</SUBJECT> <PG>20</PG> <PT>514</PT> <SUBJECT>France</SUBJECT> <PG>25</PG> <PT>515-520</PT> <RESERVED>[Reserved]</RESERVED> <PT>521</PT> <SUBJECT>Denmark</SUBJECT> <PG>33</PG> <PT>522-599</PT> <RESERVED>[Reserved]</RESERVED> </CHAPTI> </TOC> <SUBCHAP TYPE="N"> <PRTPAGE P="5"/> <HD SOURCE="HED">SUBCHAPTER G—REGULATIONS UNDER TAX CONVENTIONS</HD> <PART> <RESERVED>PARTS 500-507 [RESERVED]</RESERVED> </PART> <PART> <EAR>Pt. 509</EAR> <HD SOURCE="HED">PART 509—SWITZERLAND</HD> <CONTENTS> <SUBPART> <HD SOURCE="HED">Subpart—General Income Tax</HD> <SECHD>Sec.</SECHD> <SECTNO>509.101</SECTNO> <SUBJECT>Introductory.</SUBJECT> <SECTNO>509.102</SECTNO> <SUBJECT>Applicable provisions of law.</SUBJECT> <SECTNO>509.103</SECTNO> <SUBJECT>Scope of the convention.</SUBJECT> <SECTNO>509.104</SECTNO> <SUBJECT>Definitions.</SUBJECT> <SECTNO>509.105</SECTNO> <SUBJECT>Industrial and commercial profits.</SUBJECT> <SECTNO>509.106</SECTNO> <SUBJECT>Control of a United States enterprise by a Swiss enterprise.</SUBJECT> <SECTNO>509.107</SECTNO> <SUBJECT>Income from operation of ships or aircraft.</SUBJECT> <SECTNO>509.108</SECTNO> <SUBJECT>Dividends.</SUBJECT> <SECTNO>509.109</SECTNO> <SUBJECT>Interest.</SUBJECT> <SECTNO>509.110</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <SECTNO>509.111</SECTNO> <SUBJECT>Real property income and natural resource royalties.</SUBJECT> <SECTNO>509.112</SECTNO> <SUBJECT>Compensation for labor or personal services.</SUBJECT> <SECTNO>509.113</SECTNO> <SUBJECT>Government wages, salaries, and pensions.</SUBJECT> <SECTNO>509.114</SECTNO> <SUBJECT>Private pensions and life annuities.</SUBJECT> <SECTNO>509.115</SECTNO> <SUBJECT>Visiting professors or teachers.</SUBJECT> <SECTNO>509.116</SECTNO> <SUBJECT>Students or apprentices.</SUBJECT> <SECTNO>509.117</SECTNO> <SUBJECT>Dividends and interest paid by a foreign corporation.</SUBJECT> <SECTNO>509.118</SECTNO> <SUBJECT>Credit against United States tax for Swiss tax.</SUBJECT> <SECTNO>509.120</SECTNO> <SUBJECT>Double taxation claims.</SUBJECT> <SECTNO>509.121</SECTNO> <SUBJECT>Beneficiaries of an estate or trust.</SUBJECT> </SUBPART> </CONTENTS> <AUTH> <HD SOURCE="HED">Authority:</HD> <P>26 U.S.C. 62, 3791 and 7805.</P> </AUTH> <SUBPART> <HD SOURCE="HED">Subpart—General Income Tax</HD> <SOURCE> <HD SOURCE="HED">Source:</HD> <P>T.D. 6149, 20 FR 7587, Oct. 12, 1955; 25 FR 14022, Dec. 31, 1960, unless otherwise noted.</P> </SOURCE> <SECTION> <SECTNO>§ 509.101</SECTNO> <SUBJECT>Introductory.</SUBJECT> <P>The income tax convention between the United States and the Swiss Confederation, signed May 24, 1951, and proclaimed by the President of the United States on October 1, 1951, subject to the understanding expressed in the protocol of exchange, referred to in this part as the convention, provides as follows, effective for taxable years beginning on or after January 1, 1951:</P> <EXTRACT> <HD SOURCE="HD1">Article I</HD> <P>(1) The taxes referred to in this Convention are:</P> <P>(a) In the case of the United States of America: The Federal income taxes, including surtaxes and excess profits taxes.</P> <P>(b) In the case of The Swiss Confederation: The federal, cantonal and communal taxes on income (total income, earned income, income from property, industrial and commercial profits, etc.).</P> <P>(2) The present Convention shall also apply to any other income or profits tax of a substantially similar character imposed by either contracting State subsequently to the date of signature of the present Convention.</P> <HD SOURCE="HD1">Article II</HD> <P>(1) As used in this Convention:</P> <P>(a) The term “United States” means the United States of America, and when used in a geographical sense means the States, the Territories of Alaska and Hawaii, and the District of Columbia.</P> <P>(b) The term “Switzerland” means The Swiss Confederation.</P> <P> (c) The term “permanent establishment” means a branch, office, factory, workshop, warehouse or other fixed place of business, but does not include the casual and temporary use of merely storage facilities, nor does it include an agency unless the agent has and habitually exercises a general authority to negotiate and conclude contracts on behalf of an enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. An enterprise of one of the contracting States shall not be deemed to have a permanent establishment in the other State merely because it carries on business dealings in such other State through a commission agent, broker or custodian or other independent agent acting in the ordinary course of his business as such. The fact that an enterprise of one of the contracting States maintains in the other State a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute such fixed place of business a permanent establishment of such enterprise. The fact that a corporation of one contracting State has a subsidiary corporation which is a corporation of the other State or which is engaged in trade or business in the other State shall not of itself constitute that subsidiary corporation a permanent establishment of its parent corporation. The maintenance within the territory of one of the contracting States by an enterprise of the other contracting State of a warehouse for convenience of delivery and not for purposes of display shall not of itself constitute a permanent establishment within that territory even though offers of purchase have been obtained by an agent of the <PRTPAGE P="6"/> enterprise in that territory and transmitted by him to the enterprise for acceptance. </P> <P>(d) The term “enterprise of one of the contracting States” means, as the case may be, “United States enterprise” or “Swiss enterprise”.</P> <P>(e) The term “United States enterprise” means an industrial or commercial enterprise or undertaking carried on in the United States by a resident (including an individual, fiduciary and partnership) of the United States or by a United States corporation or other entity; the term “United States corporation or other entity” means a corporation or other entity created or organized under the law of the United States or of any State or Territory of the United States.</P> <P>(f) The term “Swiss enterprise” means an industrial or commercial enterprise or undertaking carried on in Switzerland by an individual resident in Switzerland or by a Swiss corporation or other entity; the term “Swiss corporation or other entity” means a corporation or institution or foundation having juridical personality, or a partnership (association “en nom collectif” or “en commandite”), or other association without juridical personality, created or organized under Swiss laws.</P> <P>(g) The term “competent authorities” means, in the case of the United States, the Commissioner of Internal Revenue as authorized by the Secretary of the Treasury; and in the case of Switzerland, the Director of the Federal Tax Administration as authorized by the Federal Department of Finances and Customs.</P> <P>(h) The term “industrial or commercial profits” includes manufacturing, mercantile, mining, financial and insurance profits, but does not include income in the form of dividends, interest, rents or royalties, or remuneration for personal services: Provided, however, that such excepted items of income shall, subject to the provisions of this Convention, be taxed separately or together with industrial or commercial profits in accordance with the laws of the contracting States.</P> <P>(2) In the application of the provisions of the present Convention by one of the contracting States any term not otherwise defined shall, unless the context otherwise requires, have the meaning which such term has under its own tax laws.</P> <HD SOURCE="HD1">Article III</HD> <P>(1)(a) A Swiss enterprise shall not be subject to taxation by the United States in respect of its industrial and commercial profits unless it is engaged in trade or business in the United States through a permanent establishment situated therein. If it is so engaged the United States may impose its tax upon the entire income of such enterprise from sources within the United States.</P> <P>(b) A United States enterprise shall not be subject to taxation by Switzerland in respect of its industrial and commercial profits except as to such profits allocable to its permanent establishment situated in Switzerland.</P> <P>(2) No account shall be taken in determining the tax in one of the contracting States of the mere purchase of merchandise therein by an enterprise of the other State.</P> <P>(3) Where an enterprise of one of the contracting States is engaged in trade or business in the territory of the other contracting State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits which it might be expected to derive if it were an independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment.</P> <P>(4) In the determination of the industrial or commercial profits of the permanent establishment there shall be allowed as deductions all expenses which are reasonably applicable to the permanent establishment, including executive and general administrative expenses so applicable.</P> <P>(5) The competent authorities of the two contracting States may lay down rules by agreement for the apportionment of industrial and commercial profits.</P> <HD SOURCE="HD1">Article IV</HD> <P>Where an enterprise of one of the contracting States, by reason of its participation in the management or the financial structure of an enterprise of the other contracting State, makes with or imposes on the latter, in their commercial or financial relations, conditions different from those which would be made with an independent enterprise, any profits which would normally have accrued to one of the enterprises, but by reason of those conditions have not so accrued, may be included in the profits of that enterprise and taxed accordingly.</P> <HD SOURCE="HD1">Article V</HD> <P>Income which an enterprise of one of the contracting States derives from the operation of ships or aircraft registered in that State shall be taxable only in the State in which such ships or aircraft are registered.</P> <HD SOURCE="HD1">Article VI</HD> <P> (1) The rate of tax imposed by one of the contracting States upon dividends derived from sources within such State by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall not exceed 15 percent: Provided, however, that this paragraph shall have no application to Swiss tax in the case of dividends derived from Switzerland by a Swiss citizen (who is <PRTPAGE P="7"/> not also a citizen of the United States) resident in the United States. </P> <P>(2) It is agreed, however, that such rate of tax shall not exceed five percent if the shareholder is a corporation controlling, directly or indirectly, at least 95 percent of the entire voting power in the corporation paying the dividend, and if not more than 25 percent of the gross income of such paying corporation is derived from interest and dividends, other than interest and dividends received from its own subsidiary corporations. Such reduction of the rate to five percent shall not apply if the relationship of the two corporations has been arranged or is maintained primarily with the intention of securing such reduced rate.</P> <P>(2) Switzerland may collect its tax without regard to paragraphs (1) and (2) of this Article but will make refund of the tax so collected in excess of the tax computed at the reduced rates provided in such paragraphs.</P> <HD SOURCE="HD1">Article VII</HD> <P>(1) The rate of tax imposed by one of the contracting States on interest on bonds, securities, notes, debentures or on any other form of indebtedness (including mortgages or bonds secured by real property) derived from sources within such contracting State by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall not exceed five percent: Provided, however, that this paragraph shall have no application to Swiss tax in the case of interest derived from Switzerland by a Swiss citizen (who is not also a citizen of the United States) resident in the United States.</P> <P>(2) Switzerland may collect its tax without regard to paragraph (1) of this Article but will make refund of the tax so collected in excess of the tax computed at the reduced rate provided in such paragraph.</P> <HD SOURCE="HD1">Article VIII</HD> <P>Royalties and other amounts derived, as consideration for the right to use copyrights, artistic and scientific works, patents, designs, plans, secret processes and formulae, trademarks, and other like property and rights (including rentals and like payments in respect to motion picture films or for the use of industrial, commercial or scientific equipment), from sources within one of the contracting States by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall be exempt from taxation in such former State.</P> <HD SOURCE="HD1">Article IX</HD> <P>(1) Income from real property (including gains derived from the sale or exchange of such property but not including interest from mortgages or bonds secured by real property) and royalties in respect of the operation of mines, quarries, or other natural resources, shall be taxable only in the contracting State in which such property, mines, quarries, or other natural resources are situated.</P> <P>(2) A resident or corporation or other entity of one of the contracting States deriving any such income from such property within the other contracting State may, for any taxable year, elect to be subject to the tax of such other contracting State, on a net basis, as if such resident or corporation or entity were engaged in trade or business within such other contracting State through a permanent establishment therein during such taxable year.</P> <HD SOURCE="HD1">Article X</HD> <P>(1) An individual resident of Switzerland shall be exempt from United States tax upon compensation for labor or personal services performed in the United States (including the practice of the liberal professions and rendition of services as director) if he is temporarily present in the United States for a period or periods not exceding a total of 188 days during the taxable year and either of the following conditions is met:</P> <P>(a) His compensation is received for such labor or personal services performed as an employee of, or under contract with, a resident or corporation or other entity of Switzerland, or</P> <P>(b) His compensation received for such labor or personal services does not exceed $10,000.</P> <P>(2) The provisions of paragraph (1) of this Article shall apply mutatis mutandis, to an individual resident of the United States with respect to compensation for such labor or personal services performed in Switzerland.</P> <P>(3) The provisions of this Article shall have no application to the income to which Article XI (1) relates.</P> <P>(4) The provisions of paragraph (1)(a) of this Article shall not apply to the compensation, profits, emoluments or other remuneration of public entertainers such as stage, motion picture or radio artists, musicians and athletes.</P> <HD SOURCE="HD1">Article XI</HD> <P>(1)(a) Wages, salaries and similar compensation, and pensions paid by the United States or by the political subdivisions or territories thereof to an individual (other than a Swiss citizen who is not also a citizen of the United States) shall be exempt from Swiss tax.</P> <P> (b) Wages, salaries and similar compensation and pensions paid by Switzerland or by any agency or instrumentality thereof or by any political subdivisions or other public authorities thereof to an individual (other than <PRTPAGE P="8"/> a United States citizen who is not also a citizen of Switzerland) shall be exempt from United States tax. </P> <P>(2) Private pensions and life annuities derived from within one of the contracting States and paid to individuals residing in the other contracting State shall be exempt from taxation in the former State.</P> <P>(3) The term “pensions”, as used in this Article, means periodic payments made in consideration for services rendered or by way of compensation for injuries received.</P> <P>(4) The term “life annuities” as used in this Article, means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration in money or money's worth.</P> <HD SOURCE="HD1">Article XII</HD> <P>A professor or teacher, a resident of one of the contracting States, who temporarily visits the other contracting State for the purpose of teaching for a period not exceeding two years at a university, college, school or other educational institution in the other contracting State, shall be exempted in such other contracting State from tax on his remuneration for such teaching for such period.</P> <HD SOURCE="HD1">Article XIII</HD> <P>A student or apprentice, a resident of one of the contracting States, who temporarily visits the other contracting State exclusively for the purposes of study or for acquiring business or technical experience shall not be taxable in the latter State in respect of remittances received by him from abroad for the purposes of his maintenance or studies.</P> <HD SOURCE="HD1">Article XIV</HD> <P>(1) Dividends and interest paid by a corporation other than a United States domestic corporation shall be exempt from United States tax where the recipient is a nonresident alien as to the United States resident in Switzerland or a Swiss corporation, not having a permanent establishment in the United States.</P> <P>(2) Dividends and interest paid by a corporation other than a Swiss corporation shall be exempt from Swiss tax where the recipient is a resident or corporation of the United States, not having a permanent establishment in Switzerland.</P> <HD SOURCE="HD1">Article XV</HD> <P>(1) It is agreed that double taxation shall be avoided in the following manner:</P> <P>(a) The United States in determining its taxes specified in Article I of this Convention in the case of its citizens, residents or corporations may, regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States as if this Convention had not come into effect. The United States shall, however, subject to the provisions of section 131, Internal Revenue Code, as in effect on the date of the entry into force of this Convention, deduct from its taxes the amount of Swiss taxes specified in Article I of this Convention. It is agreed that by virtue of the provisions of subparagraph (b) of this paragraph, Switzerland satisfies the similar credit requirement set forth in section 131(a)(3), Internal Revenue Code.</P> <P>(b) Switzerland, in determining its taxes specified in Article I of this Convention in the case of its residents, corporations or other entities, shall exclude from the basis upon which such taxes are imposed such items of income as are dealt with in this Convention, derived from the United States and not exempt from, and not entitled to the reduced rate of, United States tax under this Convention; but in the case of a citizen of the United States resident in Switzerland there shall be excluded all items of income derived from the United States. Switzerland, however, reserves the right to take into account in the determination of the rate of its taxes also the income excluded as provided in this paragraph.</P> <P>(2) The provisions of this Article shall not be construed to deny the exemptions from United States tax or Swiss tax, as the case may be, granted by Article XI (1) of this Convention.</P> <HD SOURCE="HD1">Article XVI</HD> <P>(1) The competent authorities of the contracting States shall exchange such information (being information available under the respective taxation laws of the contracting States) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the like in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.</P> <P> (2) Each of the contracting States may collect such taxes imposed by the other contracting State as though such taxes were the taxes of the former State as will ensure that the exemption or reduced rate of tax granted under Articles VI, VII, VIII and XI(2) of the present Convention by such other State shall not be enjoyed by persons not entitled to such benefits. <PRTPAGE P="9"/> </P> <P>(3) In no case shall the provisions of this Article be construed so as to impose upon either of the contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either contracting State or which would be contrary to its sovereignty, security or public policy or to supply particulars which are not procurable under its own legislation or that of the State making application.</P> <HD SOURCE="HD1">Article XVII</HD> <P>(1) Where a taxpayer shows proof that the action of the tax authorities of the contracting States has resulted, or will result, in double taxation contrary to the provisions of the present Convention, he shall be entitled to present the facts to the State of which he is a citizen or a resident, or, if the taxpayer is a corporation or other entity, to the State in which it is created or organized. Should the taxpayer's claim be deemed worthy of consideration, the competent authority of such State shall undertake to come to an agreement with the competent authority of the other State with a view to equitable avoidance of the double taxation in question.</P> <P>(2) Should any difficulty or doubt arise as to the interpretation or application of the present Convention, or its relationship to Conventions between one of the contracting States and any other State, the competent authorities of the contracting States may settle the question by mutual agreement.</P> <HD SOURCE="HD1">Article XVIII</HD> <P>(1) The provisions of this Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions now enjoyed or which may hereafter be granted to such officers.</P> <P>(2) The provisions of the present Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded by the laws of one of the contracting States in the determination of the tax imposed by such State.</P> <P>(3) The citizens of one of the contracting States shall not, while resident in the other contracting State, be subjected therein to other or more burdensome taxes than are the citizens of such other contracting State residing in its territory. The term “citizens” as used in this Article includes all legal persons, partnerships and associations created or organized under the laws in force in the respective contracting States. In this Article the word “taxes” means taxes of every kind or description, whether Federal, State, cantonal, municipal or communal.</P> <HD SOURCE="HD1">Article XIX</HD> <P>(1) The competent authorities of the two contracting States may prescribe regulations necessary to carry into effect the present Convention within the respective States.</P> <P>(2) The competent authorities of the two contracting States may communicate with each other directly for the purpose of giving effect to the provisions of this Convention.</P> <HD SOURCE="HD1">Article XX</HD> <P>(1) The present Convention shall be ratified and the instruments of ratification shall be exchanged at Berne as soon as possible. It shall have effect for the taxable years beginning on or after the first day of January of the year in which such exchange takes place: Provided, however, that if such exchange takes place on or after October 1 of such year, Article VI (except paragraph (2) thereof) and Article VII of the Convention shall have effect only for taxable years beginning on or after the first day of January of the year immediately following the year in which such exchange takes place.</P> <P>(2) The present Convention shall continue effective for a period of five years beginning with the calendar year in which the exchange of the instruments of ratification takes place and indefinitely after that period, but may be terminated by either of the contracting States at the end of the five-year period or at any time thereafter, provided that at least six months' prior notice of termination has been given and, in such event, the present Convention shall cease to be effective for the taxable years beginning on or after the first day of January next following the expiration of the six-month period.</P> <P>Done at Washington, in duplicate, in the English and German languages, the two texts having equal authenticity, this 24th day of May, 1951.</P> <P>For the President of the United States of America:</P> <P> [ <E T="04">seal</E> ] </P> <NAME> <E T="04">Dean Acheson.</E> </NAME> <P>For the Swiss Federal Council:</P> <P> [ <E T="04">seal</E> ] </P> <NAME> <E T="04">Charles Bruggmann.</E> </NAME> <HD SOURCE="HD1">Proclamation by the President of the United States Dated October 1, 1951</HD> <STARS/> <P>And whereas the Senate of the United States of America, by their resolution of September 17, 1951, two-thirds of the Senators present concurring therein, did advise and consent to the ratification of the aforesaid convention, subject to a reservation, as follows:</P> <P> “The Government of the United States of America does not accept paragraph (4) of Article X of the Convention, relating to the <PRTPAGE P="10"/> profits or remuneration of public entertainers.” </P> <P>And whereas the text of the aforesaid reservation was communicated by the Government of the United States of America to the Government of the Swiss Confederation and the aforesaid reservation was accepted by the Government of the Swiss Confederation;</P> <P>And whereas the aforesaid convention was duly ratified by the President of the United States of America on September 20, 1951, in pursuance of the aforesaid advice and consent of the Senate and subject to the aforesaid reservation, and the aforesaid convention was duly ratified on the part of the Swiss Confederation;</P> <P>And whereas the respective instruments of ratification of the aforesaid convention were duly exchanged at Bern on September 27, 1951, and a protocol of exchange of instruments of ratification, in the English and French languages, was signed at that place and on that date by the respective Plenipotentiaries of the United States of America and the Swiss Confederation, the said protocol containing a statement that it is understood by the two Governments that the convention aforesaid, upon entry into force in accordance with its provisions, is modified in accordance with the aforesaid reservation, so that, in effect, paragraph (4) of Article X of the convention is deemed to be deleted;</P> <P>And whereas, so far as appertains to an exchange of instruments of ratification prior to October 1 of any year, it is provided in Article XX of the aforesaid convention that upon the exchange of instruments of ratification the convention shall have effect for the taxable years beginning or [sic] or after the first day of January of the year in which such exchange takes place;</P> <P> Now, therefore, be it known that I, Harry S. Truman, President of the United States of America, do hereby proclaim and make public the aforesaid convention to the end that the said convention and each and every article and clause thereof, subject to the aforesaid reservation, may be observed and fulfilled with good faith by the United States of America and by the citizens of the United States of America and all other persons subject to the jurisdiction thereof. <STARS/> </P> </EXTRACT> </SECTION> <SECTION> <SECTNO>§ 509.102</SECTNO> <SUBJECT>Applicable provisions of law.</SUBJECT> <P> (a) <E T="03">General.</E> The Internal Revenue Code of 1954 provides in part as follows: </P> <EXTRACT> <HD SOURCE="HD1">Subtitle A—Income Taxes</HD> <STARS/> <P> <E T="04">Sec.</E> 894. <E T="03">Income exempt under treaty.</E> Income of any kind, to the extent required by any treaty obligation of the United States, shall not be included in gross income and shall be exempt from taxation under this subtitle. <STARS/> </P> <HD SOURCE="HD1">Subtitle F—Procedure and Administration</HD> <STARS/> <P> <E T="04">Sec.</E> 7805. <E T="03">Rules and regulations</E> —(a) <E T="03">Authorization.</E> Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary or his delegate shall prescribe all needful rules and regulations for the enforcement of this title, including all rules and regulations as may be necessary by reason of any alteration of law in relation to internal revenue. </P> <P> (b) <E T="03">Retroactivity of regulations or rulings.</E> The Secretary or his delegate may prescribe the extent, if any, to which any ruling or regulation, relating to the internal revenue laws, shall be applied without retroactive effect. <STARS/> </P> </EXTRACT> <P> (b) <E T="03">Internal Revenue Code of 1939.</E> Any reference in §§ 509.101 to 509.122 to any provision of the Internal Revenue Code of 1954 shall, where applicable, be deemed also to refer to the corresponding provision of the Internal Revenue Code of 1939. </P> <P> (c) <E T="03">Effective date of regulations.</E> Pursuant to sections 894 and 7805 of the Internal Revenue Code of 1954, Article XIX of the convention, and other provisions of the internal revenue laws, §§ 509.101 to 509.122 are hereby prescribed effective for taxable years beginning on or after January 1, 1951. All regulations inconsistent herewith are modified accordingly. </P> </SECTION> <SECTION> <SECTNO>§ 509.103</SECTNO> <SUBJECT>Scope of the convention.</SUBJECT> <P> (a) <E T="03">Purposes of convention.</E> The primary purposes of the convention, to be accomplished on a reciprocal basis, are to avoid double taxation upon certain items of income derived from sources in one country by residents or corporations or other entities of the other country and to provide for administrative cooperation between the competent tax authorities of the two countries looking to the avoidance of double taxation and the prevention of fiscal evasion. <PRTPAGE P="11"/> </P> <P> (b) <E T="03">Exemption from United States tax.</E> The following items of income from sources within the United States are exempt from United States tax for taxable years beginning on or after January 1, 1951, subject to the respective articles of the convention: </P> <P>(1) Industrial and commercial profits of a Swiss enterprise having no permanent establishment in the United States (Article III);</P> <P>(2) Income derived by a Swiss enterprise from the operation of ships or aircraft registered in Switzerland (Article V);</P> <P>(3) Patent and copyright royalties, and other like amounts, including motion picture film rentals, derived by a nonresident alien who is a resident of Switzerland, or by a Swiss corporation or other entity, if such alien, corporation, or other entity has no permanent establishment in the United States (Article VIII);</P> <P>(4) Compensation, subject to certain limitations, for personal services performed in the United States by a nonresident alien individual who is a resident of Switzerland (Article X);</P> <P>(5) Compensation and pensions paid by Switzerland to an alien individual, and to a citizen of Switzerland who is also a citizen of the United States, including such items as are from sources without the United States (Article XI);</P> <P>(6) Private pensions and life annuities paid to a nonresident alien individual who is a resident of Switzerland (Article XI);</P> <P>(7) Remuneration derived from certain teaching in the United States by a professor or teacher who is a nonresident alien residing in Switzerland (Article XII); and</P> <P>(8) Dividends and interest paid by a foreign corporation to a nonresident alien who is a resident of Switzerland, or to a Swiss corporation, if such alien or corporation has no permanent establishment in the United States (Article XIV).</P> <P> (c) <E T="03">Students or apprentices.</E> Remittances received from abroad for the purpose of maintenance or studies by a student or apprentice, a nonresident alien residing in Switzerland, who is temporarily present in the United States under specified circumstances are also exempt from United States tax (Article XIII). </P> <P> (d) <E T="03">Reduced rates of United States tax.</E> Dividends and interest derived from sources within the United States by a nonresident alien who is a resident of Switzerland, or by a Swiss corporation or other entity, are subject to United States tax at reduced rates, if such alien, corporation, or other entity has no permanent establishment in the United States (Articles VI and VII). </P> <P>(e) [Reserved]</P> <P> (f) <E T="03">United States citizens, residents, and corporations.</E> (1) Any citizen of Switzerland who is a resident of the United States is liable to United States tax as though the convention had not come into effect; however, such alien resident of the United States is entitled to the foreign tax credit in accordance with Article XV and is also entitled to the benefits of Article XI (1) and Article XVIII. </P> <P>(2) A citizen of the United States, even though resident in Switzerland, or a domestic corporation, even though engaged in trade or business in Switzerland through a permanent establishment situated therein, is also liable to United States tax as though the convention had not come into effect but is entitled to the foreign tax credit and, to the extent, applicable, to the benefits of Article XI (1).</P> <P> (g) <E T="03">Other provisions applicable to Swiss residents and corporations.</E> Except as otherwise expressly provided by the convention, the United States tax liability of a nonresident alien who is a resident of Switzerland, or of a Swiss corporation or other entity, is determined in accordance with the provisions of the Internal Revenue Code of 1954 relating to nonresident alien individuals and foreign corporations. </P> <CITA>[ T.D. 6149, 20 FR 7587, Oct. 12, 1955; 25 FR 14022, Dec. 31, 1960, as amended by T.D. 8734, 62 FR 53497, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 509.104</SECTNO> <SUBJECT>Definitions.</SUBJECT> <P> (a) <E T="03">General.</E> Any term defined in the convention or §§ 509.101 to 509.122 shall have the meaning so assigned to it; any term not so defined shall, unless the context otherwise requires, have the meaning which such term has under the internal revenue laws of the United States. <PRTPAGE P="12"/> </P> <P> (b) <E T="03">Specific terms.</E> As used in §§ 509.101 to 509.122— </P> <P> (1) <E T="03">United States tax.</E> The term “United States tax” means the Federal income taxes, including surtaxes and excess profits taxes, and any other income or profits tax of a substantially similar character imposed by the United States after May 24, 1951. </P> <P> (2) <E T="03">Swiss tax.</E> The term “Swiss tax” means the federal, cantonal, and communal taxes on income—that is, on total income, earned income, income from property, industrial and commercial profits, etc.—and any other income or profits tax of a substantially similar character imposed by Switzerland after May 24, 1951. </P> <P> (3) <E T="03">United States.</E> The term “United States” means the United States of America; and, when used in a geographical sense, means the States, the Territories of Alaska and Hawaii, and the District of Columbia. </P> <P> (4) <E T="03">Switzerland.</E> The term “Switzerland” means the Swiss Confederation. </P> <P> (5) <E T="03">Permanent establishment</E> —(i) <E T="03">Fixed place of business.</E> The term “permanent establishment” means an office, factory, workshop, warehouse, branch, or other fixed place of business, but does not include the casual and temporary use of merely storage facilities. It implies the active conduct of a business enterprise. The mere ownership, for example, of timberlands or a warehouse in the United States by a Swiss enterprise does not mean that such enterprise, in the absence of any business activity therein, has a permanent establishment in the United States. Moreover, the maintenance within the United States by a Swiss enterprise of a warehouse for convenience of delivery, and not for purposes of display, does not of itself constitute a permanent establishment in the United States, even though offers of purchase have been obtained by an agent therein of the Swiss enterprise and transmitted by him to the Swiss enterprise for acceptance. The fact that a Swiss enterprise maintains in the United States an office or other fixed place of business used exclusively for the purchase for such enterprise of goods or merchandise shall not of itself constitute such fixed place of business a permanent establishment of such enterprise. </P> <P> (ii) <E T="03">Subsidiary corporation.</E> The fact that a Swiss corporation has a domestic subsidiary corporation, or a foreign subsidiary corporation which is engaged in trade or business in the United States through a permanent establishment situated therein, does not of itself constitute either subsidiary corporation the United States permanent establishment of the Swiss parent corporation. </P> <P> (iii) <E T="03">Agency.</E> A Swiss enterprise which has an agency in the United States does not thereby have a permanent establishment in the United States, unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or unless he has a stock of merchandise from which he regularly fills orders on its behalf. If the enterprise has an agent in the United States who has power to contract on its behalf, but only at fixed prices and under conditions determined by such principal, it does not thereby necessarily have a permanent establishment in the United States. The mere fact that an agent of a Swiss enterprise—assuming he has no general authority to negotiate and conclude contracts on behalf of his principal—maintains samples, or occasionally fills orders from incidental stocks of goods maintained, in the United States does not of itself mean that such enterprise has a permanent establishment in the United States. The mere fact that salesmen, employees of a Swiss enterprise, promote the sale of their employer's products in the United States or that a Swiss enterprise transacts business in the United States by means of mail order activities does not mean that such enterprise has a permanent establishment in the United States. A Swiss enterprise shall not be deemed to have a permanent establishment in the United States merely because it carries on business dealings in the United States through a commission agent, broker, custodian, or other independent agent, acting in the ordinary course of his business as such. </P> <P> (6) <E T="03">Enterprise.</E> The term “enterprise” means any commercial or industrial enterprise or undertaking carried on by any person, for example, by an individual partnership, or corporation. It <PRTPAGE P="13"/> includes such activities as manufacturing, merchandising, mining, processing, banking, and insuring. It does not include the rendition of personal services. Hence, a nonresident alien individual who is resident of Switzerland and who performs personal services is not, merely by reason of such services, engaged in a Swiss enterprise within the meaning of the convention; consequently, his liability to United States tax is not determined under Article III of the convention, if he has not otherwise carried on a Swiss enterprise. </P> <P> (7) <E T="03">Swiss enterprise.</E> The term “Swiss enterprise” means an enterprise carried on in Switzerland by a nonresident alien individual who is a resident of Switzerland, or by a Swiss corporation or other entity. Thus, an enterprise carried on wholly outside Switzerland by a Swiss corporation is not a Swiss enterprise within the meaning of the convention. </P> <P> (8) <E T="03">Swiss corporation or other entity.</E> The term “Swiss corporation or other entity” means a corporation or institution or foundation having juridical personality, or a partnership (association “en nom collectif” or “en commandite”), or other association without juridical personality, created or organized under Swiss laws. </P> <P> (9) <E T="03">United States enterprise.</E> The term “United States enterprise” means an enterprise carried on in the United States by a resident of the United States (including an individual, fiduciary, and partnership) or by a United States corporation or other entity. </P> <P> (10) <E T="03">United States corporation or other entity.</E> The term “United States corporation or other entity” means a corporation or other entity created or organized under the law of the United States or of any State or Territory of the United States. </P> <P> (11) <E T="03">Industrial and commercial profits.</E> The term “industrial and commercial profits” means profits arising from industrial, commercial, mercantile, manufacturing, and like activities of an enterprise, including mining, financial and insurance profits. It does not include income in the form of dividends, interests, rents, royalties, or remuneration for personal services. In determining the industrial and commercial profits from sources within the United States of a Swiss enterprise, no profits shall be deemed to arise from the mere purchase of goods or merchandise within the United States by such enterprise. Moreover, in determining such profits of the United States permanent establishment of such enterprise, there shall be allowed as deductions all expenses which are reasonably applicable to the permanent establishment, including executive and general administrative expenses so applicable. See sections 861 through 864, Internal Revenue Code of 1954, and the regulations thereunder. </P> <P> (12) <E T="03">Commissioner.</E> The term “Commissioner” means the Commissioner of Internal Revenue or his authorized representative. </P> <P> (13) <E T="03">Director of the Federal Tax Administration.</E> The term “Director of the Federal Tax Administration” means the Director of the Federal Tax Administration (Direktor der eidgenoessischen Steuerverwaltung) of Switzerland. </P> </SECTION> <SECTION> <SECTNO>§ 509.105</SECTNO> <SUBJECT>Industrial and commercial profits.</SUBJECT> <P> (a) <E T="03">General.</E> (1) Article III of the convention adopts the principle that an enterprise of one of the contracting States shall not be taxable by the other contracting State upon its industrial and commercial profits unless it is engaged in trade or business in the latter State through a permanent establishment situated therein. Accordingly, a Swiss enterprise is subject to United States tax upon its industrial and commercial profits, to the extent of such profits from sources within the United States, only if it is engaged in trade or business in the United States at some time during the taxable year through a permanent establishment situated therein. </P> <P> (2) From the standpoint of the United States tax the article has application only to a Swiss enterprise and its industrial and commercial profits from sources within the United States. Thus, a nonresident alien individual who is a citizen of Switzerland, or a Swiss corporation or other entity, carrying on an enterprise which is not Swiss, is subject to tax on such income of such enterprise pursuant to section <PRTPAGE P="14"/> 871(c) or section 882(a), Internal Revenue Code of 1954, if such alien, corporation, or other entity has engaged in trade or business in the United States at any time during the taxable year, even though it has not had a permanent establishment therein at any time within such year. </P> <P> (b) <E T="03">No United States permanent establishment.</E> A Swiss enterprise is not subject to United States tax upon its industrial and commercial profits from sources within the United States, nor shall such profits be included in gross income, if it has not at any time during the taxable year engaged in trade or business in the United States through a permanent establishment situated therein. For example, if during the taxable year an enterprise carried on in Switzerland by a nonresident alien individual who is a resident of Switzerland, or by a Swiss corporation, were to sell merchandise, such as watches, dairy products, or liqueurs, in the United States through a commission agent or broker in the United States acting in the ordinary course of his business as such agent or broker, the profits arising from such sale would not be included in gross income and would be exempt from United States tax under Article III of the convention. Similarly, if during the taxable year such enterprise were to secure orders in the United States for such merchandise through its sales agents whose sole function in the United States is sales promotion, the orders being transmitted to Switzerland for acceptance, then the profits arising from such sales would not be included in gross income and would be exempt from United States tax. </P> <P> (c) <E T="03">United States permanent establishment</E> —(1) <E T="03">General.</E> A Swiss enterprise is subject to United States tax upon its industrial and commercial profits from sources within the United States to the same extent as are nonresident aliens or foreign corporations which are subject to tax pursuant to section 871(c) or section 882(a), Internal Revenue Code of 1954, if such enterprise has at any time during the taxable year engaged in trade or business in the United States through a permanent establishment situated therein. If it is so engaged, it is subject to United States tax upon its entire income from sources within the United States except to the extent otherwise exempt from United States tax. </P> <P> (2) <E T="03">Allocation of profits.</E> In the determination of the income taxable to such enterprise for purposes of the United States tax, all industrial and commercial profits from sources within the United States shall be deemed to be allocable to the permanent establishment in the United States. Hence, if a Swiss enterprise which has a permanent establishment in the United States at some time during the taxable year were to sell in the United States, through a commission agent therein acting in the ordinary course of his business as such, merchandise which has been produced in Switzerland, the profits arising from such sale would be allocable to the permanent establishment to the extent they are derived from sources within the United States, even though the sale is made independently of the permanent establishment. </P> <P> (3) <E T="03">Independent basis.</E> The industrial and commercial profits of the permanent establishment in the United States shall be determined as if the establishment were an independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length, or on an independent basis, with the enterprise of which it is a permanent establishment. </P> </SECTION> <SECTION> <SECTNO>§ 509.106</SECTNO> <SUBJECT>Control of a United States enterprise by a Swiss enterprise.</SUBJECT> <P> In effect, Article IV of the convention provides that, if a Swiss enterprise by reason of its control of a United States enterprise imposes on the latter enterprise conditions different from those which would result from normal business relations between independent enterprises, the accounts between the enterprises shall be adjusted in order to ascertain the true taxable income of each enterprise. The purpose is to place the controlled United States enterprise on a tax parity with an uncontrolled United States enterprise by determining, according to the standard of an uncontrolled enterprise, the true taxable income from the property and business of the controlled enterprise. The basic objective of the article is <PRTPAGE P="15"/> that, if the accounting records do not truly reflect the taxable income from the property and business of the United States enterprise, the Commissioner shall intervene and, by making such distributions, apportionments, or allocations as he may deem necessary of gross income, deductions, credits, or allowances, or of any item or element affecting taxable income, between the United States enterprise and the Swiss enterprise by which it is controlled or directed, shall determine the true taxable income of the United States enterprise. The provisions of section 482 of the Internal Revenue Code of 1954, and the regulations thereunder, shall, insofar as applicable, be followed in the determination of the taxable income of the United States enterprise. </P> </SECTION> <SECTION> <SECTNO>§ 509.107</SECTNO> <SUBJECT>Income from operation of ships or aircraft.</SUBJECT> <P>Under Article V of the convention so much of the income from sources within the United States of a Swiss enterprise as consists of earnings derived from the operation of ships or aircraft documented or registered in Switzerland shall not be included in gross income and shall be exempt from United States tax, even though at some time during the taxable year such enterprise has engaged in trade or business in the United States through a permanent establishment situated therein.</P> </SECTION> <SECTION> <SECTNO>§ 509.108</SECTNO> <SUBJECT>Dividends.</SUBJECT> <P> (a) <E T="03">General.</E> (1) The rate of United States tax imposed by the Internal Revenue Code of 1954 upon dividends derived from sources within the United States by a nonresident alien individual who is a resident of Switzerland, or by a Swiss corporation or other entity, shall not exceed 15 percent under the provisions of Article VI of the convention, if such alien, corporation, or other entity at no time during the taxable year in which such dividends are derived has a permanent establishment in the United States. </P> <P>(2) If, for example, a nonresident alien individual who is a resident of Switzerland performs personal services within the United States during the taxable year, but has at no time during such year a permanent establishment within the United States, he is entitled to the reduced rate of tax with respect to dividends derived in that year from United States sources, as provided in Article VI of the convention, even though under the provisions of section 871(c) of the Internal Revenue Code of 1954 he has engaged in trade or business within the United States during such year by reason of his having performed personal services therein.</P> <P> (b) <E T="03">Dividends paid by related corporation.</E> The rate of United States tax imposed by the Internal Revenue Code of 1954 upon dividends derived from sources within the United States by a Swiss corporation shall not exceed 5 percent under the provisions of Article VI (2) of the convention if: </P> <P>(1) The Swiss corporation is a shareholder which controls, directly or indirectly, at the time the dividend is paid 95 percent or more of the entire voting power in the corporation paying the dividend;</P> <P>(2) Not more than 25 percent of the gross income of the paying corporation for the three-year period immediately preceding the taxable year in which the dividend is paid consists of dividends and interest (other than dividends and interest received by such paying corporation from its own subsidiary corporations, if any);</P> <P>(3) The relationship between the paying corporation and the Swiss corporation has not been arranged or maintained primarily with the intention of securing the reduced rate of 5 percent; and</P> <P>(4) The Swiss corporation at no time during the taxable year in which such dividends are derived has a permanent establishment in the United States.</P> </SECTION> <SECTION> <SECTNO>§ 509.109</SECTNO> <SUBJECT>Interest.</SUBJECT> <P> The rate of United States tax imposed by the Internal Revenue Code of 1954 upon interest on bonds, securities, notes, debentures, or on any other form of indebtedness, including interest on obligations of the United States, obligations of instrumentalities of the United States, and mortgages and bonds secured by real property, which is derived from sources within the United States by a nonresident alien individual who is a resident of Switzerland, or by a Swiss corporation or other entity, shall not exceed 5 percent <PRTPAGE P="16"/> under the provisions of Article VII of the convention, if such alien, corporation, or other entity at no time during the taxable year in which such interest is derived has a permanent establishment in the United States. </P> </SECTION> <SECTION> <SECTNO>§ 509.110</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <P>Royalties and other amounts representing consideration for the right to use copyrights, artistic and scientific works, patents, designs, plans, secret processes and formulae, trademarks, and other like property and rights, including rentals and like payments in respect to motion picture films or for the use of industrial, commercial, or scientific equipment, which are derived from sources within the United States by a nonresident alien individual who is a resident of Switzerland, or by a Swiss corporation or other entity, are exempt from United States tax under the provisions of Article VIII of the convention if such alien, corporation, or other entity at no time during the taxable year in which such items of income are derived has a permanent establishment in the United States.</P> </SECTION> <SECTION> <SECTNO>§ 509.111</SECTNO> <SUBJECT>Real property income and natural resource royalties.</SUBJECT> <P> (a) <E T="03">General.</E> Income of whatever nature derived by a nonresident alien who is a resident of Switzerland, or by a Swiss corporation or other entity, from real property situated in the United States, including gains derived from the sale or exchange of such property, rentals from such property, and royalties in respect of the operation of mines, quarries, or other natural resources situated in the United States, is not exempt from United States tax by the convention. Such items of income are subject to taxation under the provisions of the Internal Revenue Code of 1954 generally applicable to the taxation of nonresident alien individuals and foreign corporations. See Article IX of the convention. Interest derived from mortgages and bonds secured by real property does not constitute income from real property for purposes of this section but is subject to the provisions applicable to interest generally. See § 509.109. </P> <P> (b) <E T="03">Net basis</E> —(1) <E T="03">General.</E> Notwithstanding the provisions of paragraph (a) of this section, a nonresident alien who is a resident of Switzerland, or a Swiss corporation or other entity, who during the taxable year derives from sources within the United States any income from real property as described in such paragraph may elect for such taxable year to be subject to United States tax on a net basis as though such alien, corporation, or other entity were engaged in trade or business in the United States during such year through a permanent establishment situated therein. </P> <P> (2) <E T="03">Manner of electing.</E> Such nonresident alien (including an individual, fiduciary, and member of a partnership) shall signify his election to be subject to tax on such a basis by filing Form 104B clearly marked at the top of the first page thereof as follows: “Return of Resident of Switzerland Electing to File on a Net Basis Pursuant to Article IX of Swiss Income Tax Convention”. Such corporation shall signify its election to be subject to tax on such a basis by filing Form 1120 clearly marked at the top of the first page there of as follows: “Return of Swiss Corporation Electing to File on a Net Basis Pursuant to Article IX of Swiss Income Tax Convention”. The election so signified shall be irrevocable for the taxable year for which such election is made. All income from sources within the United States, including gains from the sale or exchange of capital assets or of other property, shall be disclosed on the return so filed. See sections 871 and 882 of the Internal Revenue Code of 1954 and the regulations thereunder. </P> </SECTION> <SECTION> <SECTNO>§ 509.112</SECTNO> <SUBJECT>Compensation for labor or personal services.</SUBJECT> <P> (a) <E T="03">Exemption from tax.</E> Under Article X of the convention compensation received by a nonresident alien individual who is a resident of Switzerland for labor or personal services, including the practice of the liberal professions and the rendition of services as a director, performed in the United States shall not be included in gross income and shall be exempt from United States tax in either of the following situations: <PRTPAGE P="17"/> </P> <P> (1) <E T="03">Swiss employer.</E> Where such individual is temporarily present in the United States for a period or periods not exceeding in the aggregate a total of 183 days during a taxable year beginning on or after January 1, 1951, any compensation received by him (irrespective of when received, if received in taxable years beginning on or after January 1, 1951) for such labor or personal services performed in the United States during such year as an employee of, or under contract with, a nonresident alien (including a nonresident alien individual and fiduciary) who is a resident of Switzerland, or a Swiss corporation or other entity, whether or not such alien, corporation, or other entity is engaged in trade or business within the United States, shall not be included in gross income and shall be exempt from United States tax. </P> <P> (2) <E T="03">Other employers.</E> Where such individual is temporarily present in the United States for a period or periods not exceeding in the aggregate a total of 183 days during a taxable year beginning on or after January 1, 1951, any compensation received by him (irrespective of when received, if received in taxable years beginning on or after January 1, 1951) for such labor or personal services performed in the United States during such year shall not be included in gross income and shall be exempt from United States tax if such compensation does not exceed $10,000 in the aggregate. Thus, if a nonresident alien individual who is a resident of Switzerland performs personal services in the United States during the taxable year as an employee of a domestic corporation for which he receives compensation of $15,000 in the aggregate, none of such compensation shall be exempt from United States tax even though such individual is present in the United States during such year for a period or periods not exceeding a total of 183 days, since the aggregate compensation received is in excess of $10,000. </P> <P> (b) <E T="03">Definitions.</E> For purposes of this section, the term “compensation for labor or personal services” shall include, but shall not be limited to, the compensation, profits, emoluments, or other remuneration of public entertainers, such as, stage, motion picture, television, or radio artists, musicians, and athletes. For the allocation or segregation as between sources within, and sources without, the United States in the case of compensation for labor or personal services, see sections 861 through 864, Internal Revenue Code of 1954, and the regulations thereunder. </P> <P> (c) <E T="03">Exception.</E> The provisions of this section have no application to the income to which Article XI(1) of the convention relates. </P> </SECTION> <SECTION> <SECTNO>§ 509.113</SECTNO> <SUBJECT>Government wages, salaries, and pensions.</SUBJECT> <P> (a) <E T="03">General.</E> Under Article XI of the convention any wage, salary, or similar compensation, or any pension, paid by Switzerland or any agency or instrumentality thereof, or by any political subdivisions or other public authorities of Switzerland, to any alien individual (whether or not a resident of the United States) or to any individual who occupies the dual status of a citizen of the United States and a citizen of Switzerland shall not be included in gross income and shall be exempt from United States tax, even though at some time during the taxable year such individual has engaged in trade or business in the United States through a permanent establishment situated therein. </P> <P> (b) <E T="03">Definition.</E> As used in this section, the term “pensions” means periodic payments made in consideration for services rendered or by way of compensation for injuries received. Under Article XV(2) of the convention the exclusion from gross income, and exemption from United States tax, provided by this section shall not be denied despite the provisions of Article XV. See § 509.118. </P> <P> (c) <E T="03">Cross reference.</E> For the taxation generally of compensation of alien employees of foreign governments and the consequences of executing and filing the waiver provided for in section 247(b) of the Immigration and Nationality Act, see section 893 of the Internal Revenue Code of 1954 and the regulations thereunder. </P> </SECTION> <SECTION> <SECTNO>§ 509.114</SECTNO> <SUBJECT>Private pensions and life annuities.</SUBJECT> <P> (a) <E T="03">General.</E> Private pensions and life annuities derived from sources within <PRTPAGE P="18"/> the United States and paid to a nonresident alien individual who is a resident of Switzerland shall not be included in gross income and shall be exempt from United States tax, in accordance with Article XI of the convention, even though at some time during the taxable year such individual has engaged in trade or business in the United States through a permanent establishment situated therein. </P> <P> (b) <E T="03">Definitions.</E> As used in this section, the term “pensions” means periodic payments made in consideration for services rendered or by way of compensation for injuries received; and the term “life annuities” means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration in money or money's worth. </P> </SECTION> <SECTION> <SECTNO>§ 509.115</SECTNO> <SUBJECT>Visiting professors or teachers.</SUBJECT> <P> (a) <E T="03">General.</E> Pursuant to Article XII of the convention, a professor or teacher, a nonresident alien who is a resident of Switzerland, who temporarily visits the United States for the purpose of teaching for a period not exceeding two years at any university, college, school, or other educational institution situated within the United States shall, for a period not exceeding two years from the date of his initial arrival in the United States, be exempt from United States tax with respect to his remuneration earned in taxable years beginning on or after January 1, 1951, for such teaching during such period not in excess of two years. </P> <P> (b) <E T="03">More than two years.</E> The exemption granted by Article XII is applicable to remuneration earned during such part of the individual's visit as does not exceed two years from the date of arrival even though the total period of his presence in the United States may extend beyond two years, provided that during such entire period he may be considered to be temporarily visiting the United States. </P> <P> (c) <E T="03">Residence.</E> Such exemption shall not apply to the remuneration of an alien who is a resident of the United States or who is not a resident of Switzerland. </P> <P> (d) <E T="03">Nonresidence presumed.</E> An individual who otherwise qualifies for the exemption from United States tax granted by Article XII shall, for a period of not more than two years immediately succeeding the date of his arrival within the United States for the purpose of such teaching, be deemed to have the tax status of a nonresident alien in the absence of proof of his intention to remain indefinitely in the United States. See section 871 of the Internal Revenue Code of 1954 and the regulations thereunder. </P> </SECTION> <SECTION> <SECTNO>§ 509.116</SECTNO> <SUBJECT>Students or apprentices.</SUBJECT> <P> (a) <E T="03">General.</E> Under Article XIII of the convention, a student or apprentice, a nonresident alien who is a resident of Switzerland, who temporarily visits the United States exclusively for the purposes of study or for acquiring business or technical experience shall not include in gross income, and shall be exempt from United States tax with respect to, amounts derived by him in taxable years beginning on or after January 1, 1951, and received during such years from without the United States as remittances for the purposes of his maintenance or studies. </P> <P> (b) <E T="03">Residence.</E> The exemption shall not apply to remittances received by an alien who is a resident of the United States or who is not a resident of Switzerland. </P> </SECTION> <SECTION> <SECTNO>§ 509.117</SECTNO> <SUBJECT>Dividends and interest paid by a foreign corporation.</SUBJECT> <P>(a) [Reserved]</P> <P> (b) <E T="03">Exemption from United States tax.</E> Notwithstanding the provisions of paragraph (a) of this section, Article XIV(1) of the convention provides that dividends and interest paid by any foreign corporation and derived by a nonresident alien who is a resident of Switzerland, or by a Swiss corporation, shall not be included in gross income and shall be exempt from United States tax if such alien or corporation at no time during the taxable year in which such items of income are derived has a permanent establishment in the United States. The exemption so provided shall apply even though the corporation paying the dividends or interest is a resident foreign corporation at the time of payment and without regard to <PRTPAGE P="19"/> the percentage of its gross income from sources within the United States. </P> <CITA>[T.D. 6149, 20 FR 7587, Oct. 12, 1955; 25 FR 14022, Dec. 31, 1960, as amended by T.D. 8734, 62 FR 53497, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 509.118</SECTNO> <SUBJECT>Credit against United States tax for Swiss tax.</SUBJECT> <P> (a) <E T="03">General</E> —(1) <E T="03">Taxable as though no convention.</E> Notwithstanding any other provision of the convention the United States, in determining the United States tax of a citizen or resident of the United States, or of a domestic corporation, may, under Article XV(1)(a) of the convention, include in the basis upon which such tax is imposed all items of income taxable under the revenue laws of the United States, as though the convention had not come into effect. For example, despite the exemption from United States tax granted by Article VIII of the convention with respect to a copyright royalty derived from sources within the United States by a resident of Switzerland, such royalty shall be included in gross income and is subject to United States tax when so derived by a resident of Switzerland who is a citizen of the United States, even though such resident has no permanent establishment in the United States. </P> <P> (2) <E T="03">Exception.</E> Notwithstanding the provisions of subparagraph (1) of this paragraph, the exclusion from gross income, and exemption from United States tax, granted by Article XI(1) of the convention with respect to wages, salaries, and similar compensation, and pensions, paid by Switzerland or any agency or instrumentality thereof, or by any political subdivisions or other public authorities of Switzerland, shall not be denied. See Article XV(2) of the convention. </P> <P> (b) <E T="03">Application of credit</E> —(1) <E T="03">General.</E> For the purpose of mitigating double taxation, Article XV(1)(a) of the convention provides that a citizen or resident of the United States, or a domestic corporation, deriving income from sources within Switzerland shall be allowed a credit against the United States tax for the amount of Swiss tax paid or accrued during the taxable year. This credit shall be made in accordance with the provisions of section 131 of the Internal Revenue Code of 1939 as in effect on September 27, 1951, but subject to the provisions of Article XVIII(2) of the convention. </P> <P> (2) <E T="03">Similar credit requirement.</E> (i) Article XV(1)(a) further provides that, by virtue of the provisions of Article XV(1)(b) of the convention, relating to the exclusion from basis for computing the Swiss tax, Switzerland satisfies the similar credit requirement set forth in section 901(b)(3), Internal Revenue Code of 1954, relating to alien residents of the United States, etc. </P> <P>(ii) This provision of Article XV(1)(a) shall be taken to mean that, solely by reason of the exclusion granted by it under Article XV(1)(b) and without reference to concessions otherwise made by such country, Switzerland satisfies the similar credit requirement only with respect to taxes paid to Switzerland, and not with respect to taxes paid to another foreign country. Nothing in this subdivision shall be construed, however, to prevent Switzerland from otherwise satisfying the similar credit requirement, in accordance with section 901 of the Internal Revenue Code of 1954 and the regulations thereunder, with respect to taxes paid to another foreign country. Thus, if pursuant to a convention between Switzerland and another foreign country, Switzerland were to exempt from its income taxes the income received from sources within such other foreign country by a United States citizen residing in Switzerland, then Switzerland would, in accordance with such regulations under section 901, satisfy the similar credit requirement of section 901(b)(3) with respect to income taxes paid to such other country by a Swiss citizen residing in the United States.</P> </SECTION> <SECTION> <SECTNO>§ 509.120</SECTNO> <SUBJECT>Double taxation claims.</SUBJECT> <P> (a) <E T="03">General.</E> Under Article XVII of the convention, where the taxpayer shows proof that the action of the tax authorities of the United States or Switzerland has resulted, or will result, in double taxation contrary to the provisions of the convention, he is entitled to present the facts to the country of which he is a citizen; or, if he is not a citizen of either country, to the country of which he is a resident; or, if the <PRTPAGE P="20"/> taxpayer is a corporation or other entity, to the country in which it is created or organized. The article provides that, should the taxpayer's claim be deemed worthy of consideration, the competent authority of the country to which the facts are presented shall undertake to come to an agreement with the competent authority of the other country with a view to equitable avoidance of the double taxation in question. </P> <P> (b) <E T="03">Manner of filing claim.</E> Such a claim on behalf of a United States citizen, corporation, or other entity, or on behalf of a resident of the United States who is not a Swiss citizen, shall be filed with the Commissioner. The claim shall be set up in the form of a letter addressed to “The Commissioner of Internal Revenue, Washington, D.C.” and shall show fully all facts and laws on the basis of which the claimant alleges that such double taxation has resulted or will result. If the Commissioner determines that there is an appropriate basis for the claim under the convention, he shall take up the matter with the Director of the Federal Tax Administration with a view to arranging an agreement of the character contemplated by Article XVII. </P> </SECTION> <SECTION> <SECTNO>§ 509.121</SECTNO> <SUBJECT>Beneficiaries of an estate or trust.</SUBJECT> <P> (a) <E T="03">Qualified beneficiary.</E> If he otherwise satisfies the requirements of the respective articles concerned, a nonresident alien who is a resident of Switzerland and who is a beneficiary of an estate or trust shall be entitled to the exemption from, or reduction in the rate of, United States tax granted by Articles VI, VII, VIII, and XIV of the convention with respect to dividends, interest, and royalties and other like amounts, to the extent that (1) any amount paid, credited, or required to be distributed by such estate or trust to such beneficiary is deemed to consist of such items and (2) such items would, without regard to the convention, be includible in his gross income. </P> <P> (b) <E T="03">Amounts otherwise includible in gross income of beneficiary.</E> For the determination of amounts which, without regard to the convention, are includible in the gross income of the beneficiary, see subchapter J of chapter 1 of the Internal Revenue Code of 1954, and the regulations thereunder. </P> </SECTION> </SUBPART> </PART> <PART> <RESERVED>PARTS 510-512 [RESERVED]</RESERVED> </PART> <PART> <EAR>Pt. 513</EAR> <HD SOURCE="HED">PART 513—IRELAND</HD> <CONTENTS> <SUBPART> <HD SOURCE="HED">Subpart—Withholding of Tax</HD> <SECHD>Sec.</SECHD> <SECTNO>513.2</SECTNO> <SUBJECT>Dividends.</SUBJECT> <SECTNO>513.3</SECTNO> <SUBJECT>Interest.</SUBJECT> <SECTNO>513.4</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <SECTNO>513.5</SECTNO> <SUBJECT>Natural resource royalties and real property rentals.</SUBJECT> <SECTNO>513.6</SECTNO> <SUBJECT>Pensions and life annuities.</SUBJECT> <SECTNO>513.7</SECTNO> <SUBJECT>Release of excess tax withheld at source.</SUBJECT> <SECTNO>513.8</SECTNO> <SUBJECT>Addressee not actual owner.</SUBJECT> <SECTNO>513.9</SECTNO> <SUBJECT>Information to be furnished in ordinary course.</SUBJECT> <SECTNO>513.10</SECTNO> <SUBJECT>Beneficiaries of a domestic estate or trust.</SUBJECT> <SECTNO>513.11</SECTNO> <SUBJECT>Refund of income tax withheld during 1951.</SUBJECT> </SUBPART> </CONTENTS> <AUTH> <HD SOURCE="HED">Authority:</HD> <P>26 U.S.C. 62.</P> </AUTH> <SOURCE> <HD SOURCE="HED">Source:</HD> <P>T.D. 5897, 17 FR 3633, Apr. 24, 1952, unless otherwise noted. Redesignated at 25 FR 14022, Dec. 31, 1960.</P> </SOURCE> <SUBPART> <HD SOURCE="HED">Subpart—Withholding of Tax</HD> <SECTION> <SECTNO>§ 513.2</SECTNO> <SUBJECT>Dividends.</SUBJECT> <P>The fact that the payee of the dividend is not required to pay Irish tax on such dividend because of the application of reliefs or exemptions under Irish revenue laws does not prevent the application of the reduction in rate of United States tax with respect to such dividend. If the dividend would have been subject to Irish tax had the payee thereof derived an income large enough to require payment of tax then liability to Irish tax exists for the purpose of the reduction in rate of United States tax. As to what constitutes a permanent establishment, see Article II(1)(i) of the convention.</P> <CITA>[T.D. 8734, 62 FR 53497, Oct. 14, 1997; 63 FR 2723, Jan. 16, 1998]</CITA> </SECTION> <SECTION> <SECTNO>§ 513.3</SECTNO> <SUBJECT>Interest.</SUBJECT> <P> The provisions of § 513.2 relating to the degree of liability to Irish tax in <PRTPAGE P="21"/> the case of dividends are equally applicable with respect to the income falling within the scope of this section. </P> <CITA>[T.D. 8734, 62 FR 53497, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 513.4</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <P>The provisions of § 513.2 relating to the degree of liability to Irish tax in the case of dividends are equally applicable with respect to the income falling within the scope of this section.</P> <CITA>[T.D. 8734, 62 FR 53498, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 513.5</SECTNO> <SUBJECT>Natural resource royalties and real property rentals.</SUBJECT> <P>The provisions of § 513.2 relating to the degree of liability to Irsh tax in the case of dividends are equally applicable with respect to the income falling within the scope of this section.</P> <CITA>[T.D. 8734, 62 FR 53498, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 513.6</SECTNO> <SUBJECT>Pensions and life annuities.</SUBJECT> <P>(a) Pensions, other than pensions paid by the Government of the United States to individuals in respect of services rendered thereto in the discharge of governmental functions, and any life annuity, derived from sources within the United States in taxable years beginning on or after January 1, 1951, by a nonresident alien individual who is resident in Ireland for the purposes of Irish tax are exempt from United States tax under the provisions of Article XII of the convention.</P> <P>(b) To obviate withholding at the source in the case of such exempt income the nonresident alien individual who is resident in Ireland for the purposes of Irish tax shall notify the withholding agent by letter in duplicate that such income is exempt from United States tax under the provisions of Article XII of the convention. The letter of notification shall be signed by the owner of the income, shall show the name and address of both the payer and the owner, and shall contain a statement that the owner, an individual, is neither a citizen nor a resident of the United States but is resident in Ireland for the purposes of Irish tax. This letter shall constitute authorization for the payment of such income without deduction of the tax at source unless the Commissioner of Internal Revenue subsequently notifies the withholding agent that the tax should be withheld from payments of such income made after receipt of such notice. If, after filing a letter of notification, the owner of the income ceases to be eligible for the benefit of the convention, he must promptly notify the withholding agent by letter in duplicate.</P> <P>(c) Each letter of notification, or the duplicate thereof, must be immediately forwarded by the withholding agent to the Commissioner of Internal Revenue, Clearing Branch, Washington 25, D.C.</P> </SECTION> <SECTION> <SECTNO>§ 513.7</SECTNO> <SUBJECT>Release of excess tax withheld at source.</SUBJECT> <P> (a) <E T="03">General.</E> (1) In order to bring the convention into force and effect at the earliest practicable date, </P> <P>(i) The reduced rate of tax of 15 percent to be withheld at the source from dividends, natural resource royalties, and real property rentals, and</P> <P>(ii) The exemption from tax otherwise withheld at the source from interest, patent royalties, copyright royalties, film rentals, and the like,</P> <FP>are hereby made effective beginning January 1, 1952, in any case in which such natural resource royalties, real property rentals, interest, patent royalties, copyright royalties, film rentals, and the like are derived from sources within the United States, or in which such dividends are derived from a United States corporation, by a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) who is resident in Ireland for the purposes of Irish tax, or by a foreign corporation whose business is managed and controlled in Ireland, if such alien or corporation is subject to Irish tax on such income and at no time during the taxable year in which such income is so derived had a permanent establishment within the United States.</FP> <P> (2) In the case of every such taxpayer whose address at the time of payment was in Ireland and who furnishes to the withholding agent the letter of notification prescribed in §§ 513.3(b), 513.4, or § 513.5, where United States tax at the rate of 30 percent has been withheld on or after January 1, 1952, there shall be <PRTPAGE P="22"/> released (except as provided in paragraph (e) of this section) by the withholding agent and paid over to the person from whom it was withheld: </P> <P>(i) In the case of natural resource royalties and real property rentals, an amount equal to 15 percent of such royalties and rentals, and</P> <P>(ii) In the case of interest (other than coupon bond interest), patent royalties, copyright royalties, film rentals, and the like, an amount equal to the tax so withheld.</P> <P>(3) In the case of every such taxpayer whose address at the time of payment was in Ireland and who furnishes to the withholding agent Form 1001-IR in duplicate, where United States tax at the rate of 28 percent or 30 percent, as the case may be, has been withheld from coupon bond interest on or after January 1, 1952, there shall be released (except as provided in paragraph (e) of this section) by the withholding agent and paid over to the person from whom it was withheld an amount equal to the tax so withheld, if such taxpayer also files in duplicate with the withholding agent as authorization for the release of such amount a Form 1001-IR clearly marked “Substitute”. One such substitute form shall be filed in duplicate with respect to each issue of bonds and will serve with respect to that issue to replace all Forms 1001 previously filed by such taxpayer in the calendar year in which the excess tax is released. The use of Form 1001-IR with each presentation of interest coupons for the purpose of obviating withholding of tax at source is set forth in § 513.3(b).</P> <P>(4) In the case of dividends derived from a United States corporation and paid to a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) or to a foreign corporation, whose address at the time of payment was in Ireland, where United States tax at the rate of 30 percent has been withheld from such dividends on or after January 1, 1952, there shall be released (except as provided in paragraph (d) of this section) by the withholding agent and paid over to the person from whom it was withheld an amount equal to 15 percent of such dividends.</P> <P> (b) <E T="03">Amounts withheld during 1951.</E> For provisions respecting the refund of excess tax withheld during the calendar year 1951, see § 513.11. </P> <P> (c) <E T="03">Pensions and life annuities.</E> (1) In order to bring the convention into force and effect at the earliest practicable date the exemption from tax otherwise withheld at the source from life annuities and pensions, other than pensions paid by the Government of the United States to individuals in respect of services rendered thereto in the discharge of governmental functions, is hereby made effective beginning January 1, 1952, in any case in which such pensions and life annuities are derived from sources within the United States by a nonresident alien individual who is resident in Ireland for the purposes of Irish tax. </P> <P>(2) In the case of every such taxpayer whose address at the time of payment was in Ireland and who furnishes to the withholding agent the letter of notification prescribed in § 513.6, where United States tax at the rate of 30 percent has been withheld on or after January 1, 1952, from such pensions or life annuities, as the case may be, there shall be released by the withholding agent and paid over to the person from whom it was withheld an amount equal to the tax so withheld.</P> <P> (d) <E T="03">Subsidiary's dividends.</E> (1) United States tax shall be withheld at the rate of 15 percent from any dividend derived from a United States corporation and paid on or after January 1, 1952, to a foreign corporation whose address is in Ireland unless, prior to the date of payment thereof, the Commissioner of Internal Revenue notifies the domestic corporation that such dividend falls within the scope of the proviso of Article VI(1) of the convention. </P> <P> (2) In the case of every domestic corporation receiving notification from the Commissioner of Internal Revenue under the provisions of § 513.2(b) that dividends paid or to be paid by it fall within the scope of the proviso of Article VI(1) of the convention, where United States tax in excess of the applicable rate of 5 percent has been withheld on or after January 1, 1952, from dividends which come within the scope of such proviso, the withholding agent shall, if so authorized in such notification, release and pay over to the foreign corporation from which it was <PRTPAGE P="23"/> withheld the excess tax withheld with respect to such dividends. </P> <P> (e) <E T="03">Interest paid where degree of stock ownership is determined.</E> In the case of every foreign corporation whose address at the time of payment was in Ireland and which (1) furnishes to the domestic corporation a copy of the Commissioner's authorization of release prescribed in § 513.3(c) and (2) files the letter of notification prescribed in § 513.3(b), or the substitute Form 1001-IR prescribed in paragraph (a) of this section, whichever is applicable, where United States tax at the rate of 28 percent or 30 percent, as the case may be, has been withheld on or after January 1, 1952, the withholding agent shall release and pay over to the foreign corporation from which it was withheld an amount equal to the tax so withheld. </P> </SECTION> <SECTION> <SECTNO>§ 513.8</SECTNO> <SUBJECT>Addressee not actual owner.</SUBJECT> <P>(a) If any person with an address in Ireland who receives a dividend from a United States corporation with respect to which United States tax at the rate of only 15 percent has been withheld at source is a nominee or representative through whom such dividend flows to a person other than one described in § 513.2(a) as being entitled to such reduced rate of 15 percent, such recipient in Ireland will withhold an additional amount of United States tax equivalent to the difference between the United States tax which would have been withheld had the convention not been in effect (30 percent as of the date of approval of this subpart) and the 15 percent withheld at the source with respect to such dividend pursuant to § 513.2(d).</P> <P>(b) In any case in which a fiduciary or partnership with an address in Ireland receives, otherwise than as a nominee or representative, a dividend from a United States corporation with respect to which United States tax at the rate of only 15 percent has been withheld at source, if a beneficiary of such fiduciary or a partner in such partnership is not entitled to the reduced rate of tax provided in Article VI(1) of the convention, the fiduciary or partnership will withhold an additional amount of United States tax with respect to the portion of such dividend included in such beneficiary's share of the distributed or distributable income, or in such partner's distributive share of the income, of such fiduciary or partnership, as the case may be. The amount of the additional tax is to be calculated in the same manner as under paragraph (a) of this section.</P> <P>(c) If any amount of United States tax is released pursuant to § 513.7(a) by the withholding agent in the United States with respect to a dividend received by such a person with an address in Ireland, the latter will also withhold from such released amount any additional amount of United States tax, otherwise required to be withheld by the preceding provisions of this section in respect of such dividend, in the same manner as if at the time of payment of such dividend United States tax at the rate of only 15 percent had been withheld at source therefrom.</P> <P>(d) The amounts so withheld by such withholding agents in Ireland will be deposited, without converting such amounts into United States dollars, with the Irish Revenue Commissioners on or before the 15th day after the close of the calendar year quarter in which such withholding in Ireland occurs. Each withholding agent making such deposit will render therewith the appropriate Irish form as prescribed in regulations made by the Revenue Commissioners. The Revenue Commissioners have arranged that the amounts so deposited will be remitted by draft in United States dollars to the District Director of Internal Revenue, Baltimore, Maryland, U.S.A., on or before the end of the calendar month in which the deposits are made, such draft to be accompanied by the Irish form rendered by the withholding agents in Ireland in connection with such deposits.</P> </SECTION> <SECTION> <SECTNO>§ 513.9</SECTNO> <SUBJECT>Information to be furnished in ordinary course.</SUBJECT> <P> In compliance with the provisions of Article XX of the convention the Commissioner of Internal Revenue will transmit to the Irish Revenue Commissioners, as soon as practicable after the close of the calendar year 1952 and of each subsequent calendar year during which the convention is in effect, the <PRTPAGE P="24"/> following information relating to such preceding calendar year: </P> <P>(a) The name and address of each person whose address as disclosed on each available Form 1042 is in Ireland deriving from sources within the United States dividends, interest, rent, royalties, salaries, wages, pensions, annuities, and other fixed or determinable annual or periodical income; and the amount of such income as disclosed on such form with respect to each such person.</P> <P>(b) The duplicate copy of each available ownership certificate, Form 1001-IR, filed pursuant to § 513.3(b), and substitute Form 1001-IR, filed pursuant to § 513.7(a), in connection with coupon bond interest.</P> </SECTION> <SECTION> <SECTNO>§ 513.10</SECTNO> <SUBJECT>Beneficiaries of a domestic estate or trust.</SUBJECT> <P>A nonresident alien who is resident in Ireland for the purposes of Irish tax and who is a beneficiary of a domestic estate or trust shall be entitled to the exemption from, or reduction in the rate of, United States tax provided in Articles VI, VII, VIII, IX, and XV of the convention with respect to dividends, interest, royalties, natural resource royalties, and real property rentals to the extent such item or items are included in his share of the distributed or distributable income of such estate or trust. In order to be entitled in such instance to the exemption from, or reduction in the rate of, tax such beneficiary must otherwise satisfy the requirements of these respective Articles of the convention and must, where applicable, execute and submit to the fiduciary of such estate or trust in the United States the appropriate letter of notification prescribed in §§ 513.3(b), 513.4, and 513.5.</P> </SECTION> <SECTION> <SECTNO>§ 513.11</SECTNO> <SUBJECT>Refund of income tax withheld during 1951.</SUBJECT> <P>(a) If United States tax withheld at the source during the year 1951 from dividends, interest, royalties, natural resource royalties, real property rentals, pensions, or life annuities is in excess of the tax imposed by Chapter 1 (relating to the income tax) of the Internal Revenue Code, as modified by the convention, claim by the taxpayer for the refund of any overpayment shall be made under section 322 of the Internal Revenue Code by filing Form 843 together with Form 1040NB, Form 1040NB-a, Form 1040B, or Form 1120NB, whichever is applicable, or with an amended return.</P> <P>(b) The taxpayer's total gross income from sources within the United States, including every item of capital gain subject to tax under the provisions of section 211(a)(1)(B) or 211(c) of the Internal Revenue Code, shall be disclosed on the return. In the event that securities are held in the name of a person other than the actual or beneficial owner, the name and address of such person must be furnished with the claim. There shall also be included in such claim for refund a statement:</P> <P>(1) That the taxpayer was, at the time when the item or items of income were derived, (i) a nonresident alien (including a nonresident alien individual, fiduciary, or partnership) who at such time was resident in Ireland for the purposes of Irish tax, or (ii) a foreign corporation whose business at such time was managed and controlled in Ireland.</P> <P>(2) That the taxpayer at no time during the taxable year in which the income was derived had a permanent establishment in the United States.</P> <P>(3) That the taxpayer is subject to Irish tax on the item or items of income for which the benefit of the convention is claimed.</P> <P>(c) If, however, the taxpayer is an individual who during the taxable year derived from sources within the United States income which consists exclusively of pensions or life annuities entitled to the benefit of Article XII of the convention, the statements specified in paragraph (b) (2) and (3) of this section will not be required.</P> <P>(d) As to additional information required in the case of a foreign corporation claiming the benefit of the 5 percent rate on dividends, or in certain doubtful cases the benefit of the exemption with respect to interest, paid by a domestic corporation, see § 513.2(b) or § 513.3(c).</P> </SECTION> </SUBPART> </PART> <PART> <PRTPAGE P="25"/> <EAR>Pt. 514</EAR> <HD SOURCE="HED">PART 514—FRANCE</HD> <CONTENTS> <SUBPART> <HD SOURCE="HED">Subpart—Withholding of Tax</HD> <SECHD>Sec.</SECHD> <SECTNO>514.1</SECTNO> <SUBJECT>Introductory.</SUBJECT> <SECTNO>514.2</SECTNO> <SUBJECT>Dividends.</SUBJECT> <SECTNO>514.3</SECTNO> <SUBJECT>Dividends received by addressee not actual owner.</SUBJECT> <SECTNO>514.4</SECTNO> <SUBJECT>Interest.</SUBJECT> <SECTNO>514.5</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <SECTNO>514.6</SECTNO> <SUBJECT>Private pensions and life annuities.</SUBJECT> <SECTNO>514.7</SECTNO> <SUBJECT>Beneficiaries of a domestic estate or trust.</SUBJECT> <SECTNO>514.8</SECTNO> <SUBJECT>Release of excess tax withheld at source.</SUBJECT> <SECTNO>514.9</SECTNO> <SUBJECT>Refund of excess tax withheld.</SUBJECT> <SECTNO>514.10</SECTNO> <SUBJECT>Effective date.</SUBJECT> <SUBJGRP> <HD SOURCE="HED">Taxable Years Beginning After December 31, 1966, or Dividends, Interest, And Royalties Paid on or After August 11, 1968</HD> <SECTNO>514.22</SECTNO> <SUBJECT>Dividends received by persons not entitled to reduced rate of tax.</SUBJECT> </SUBJGRP> </SUBPART> </CONTENTS> <AUTH> <HD SOURCE="HED">Authority:</HD> <P>26 U.S.C. 7805.</P> </AUTH> <SUBPART> <HD SOURCE="HED">Subpart—Withholding of Tax</HD> <SOURCE> <HD SOURCE="HED">Source:</HD> <P>T.D. 6273, 22 FR 9530, Nov. 28, 1957; 25 FR 14022, Dec. 31, 1960, unless otherwise noted.</P> </SOURCE> <SECTION> <SECTNO>§ 514.1</SECTNO> <SUBJECT>Introductory.</SUBJECT> <P> (a) <E T="03">Applicable provisions of convention.</E> The income tax convention between the United States and France, signed on July 25, 1939, and October 18, 1946, as modified by the supplemental convention, signed June 22, 1956 (the instruments of ratification of which were exchanged on June 13, 1957), referred to in this part as the convention, provides in part as follows, the quoted articles being effective as indicated: </P> <EXTRACT> <P>Article I(a) of the Supplemental Convention of 1956, on June 13, 1957.</P> <P>Article I(d) of the Supplemental Convention of 1956, on January 1, 1952.</P> <P>Article 7 and the Protocol of the Convention of 1939, on January 1, 1945.</P> <P>The supplemental convention signed June 22, 1956, provides in part as follows:</P> <HD SOURCE="HD1">Article I</HD> <P>The provisions of the Convention and Protocol between the United States and the French Republic signed at Paris on July 25, 1939 are hereby modified and supplemented as follows:</P> <P>(a) By striking out Article 1(a) and inserting in lieu thereof the following:</P> <P> “(a) In the case of the United States: The Federal income taxes (including surtaxes and excess profits taxes) and the documentary taxes on sales or transfers of shares or certificates of stock or bonds.” <STARS/> </P> <P>(d) By adding immediately after Article 6 the following new articles:</P> <HD SOURCE="HD1">“Article 6A</HD> <P> Dividends and interest derived, on or after January 1, 1952, from sources within one of the contracting States by a resident or corporation or other entity of the other State, not having a permanent establishment in the former State shall be subject to tax by such former State at a rate not in excess of 15 percent of the gross amount of such dividends or interest. Such reduced rate of tax shall not apply to dividends or interest paid prior to the calendar year in which are exchanged the instruments of ratification of the present Convention if, for the taxable year in which such dividends or interest is received, penalty for fraud with respect to the taxes which are the subject of the present Convention has been imposed against the recipient of such dividends or interest.” <STARS/> </P> <HD SOURCE="HD1">Article III</HD> <P>(a) The present Convention shall be ratified and the instruments of ratification shall be exchanged at Paris as soon as possible.</P> <P> (b) Its provisions shall come into force and shall become effective as of the date of the exchange of the instruments of ratification subject both to the provisions of Article I (d) and (e) and to the provisions set forth herein below. <STARS/> </P> <P>(c) If refund of any overpayment resulting from the application of Article I(d) of the present Convention is prevented on the date of exchange of instruments of ratification or within two years from such date by the operation of any law, refund of such overpayment (without interest) shall nevertheless be made provided that claim for refund is filed within two years after the date of the exchange of instruments of ratification of the present Convention with the contracting State to which such overpayment was made.</P> <P>(d) The present Convention shall remain effective so long as the Conventions signed July 25, 1939 and October 18, 1946, remain effective.</P> <P> The convention of July 25, 1939, provides, in part, as follows: <PRTPAGE P="26"/> </P> <HD SOURCE="HD1">Article 7</HD> <STARS/> <P>Royalties derived from within one of the contracting States by a resident, or by a corporation or other entity of the other contracting State as consideration for the right to use copyrights, patents, secret processes and formulae, trademarks and other analogous rights shall be exempt from taxation in the former State, provided such resident, corporation or other entity does not have a permanent establishment there.</P> <HD SOURCE="HD1">Article 8</HD> <STARS/> <P>Private pensions and life annuities derived from within one of the contracting States and paid to individuals residing in the other contracting State shall be exempt from taxation in the former State.</P> <FP>Protocol:</FP> <STARS/> <P>III. As used in this Convention:</P> <P>(a) The term “permanent establishment” includes branches, mines and oil wells, plantations, factories, workshops, stores, purchasing and selling and other offices, agencies, warehouses, and other fixed places of business but does not include a subsidiary corporation.</P> <P>When an enterprise of one of the contracting States carries on business in the other State through an employee or agent, established there, who has general authority to negotiate and conclude contracts or has a stock of merchandise from which he regularly fills orders which he receives, this enterprise shall be deemed to have a permanent establishment in the latter State. But the fact that an enterprise of one of the contracting States has business dealings in the other State through a bona fide commission agent or broker shall not be held to mean that such enterprise has a permanent establishment in the latter State.</P> <P>Insurance enterprises shall be considered as having a permanent establishment in one of the States as soon as they receive premiums from or insure risks in the territory of that State.</P> <P>IV. The term “life annuities” referred to in Article 8 of this Convention means a stated sum payable periodically at stated times during life, or during a specified number of years to the person who has paid the premium or a gross sum for such an obligation.</P> <P>The convention of October 18, 1946, provides, in part, as follows:</P> <HD SOURCE="HD1">Title III</HD> <HD SOURCE="HD2">Administrative Assistance</HD> <STARS/> <HD SOURCE="HD1">Article 13</HD> <P> (1) The competent authorities of the two Contracting States may prescribe regulations necessary to interpret and carry out the provisions of the present Convention and the Convention of July 25, 1939. <STARS/> </P> </EXTRACT> <P> (b) <E T="03">Definitions</E> —(1) <E T="03">In general.</E> Any term defined in the convention or §§ 514.1 to 514.10 shall have the meaning so assigned to it; any term not so defined shall, unless the context otherwise requires, have the meaning which such term has under the internal revenue laws of the United States. </P> <P> (2) <E T="03">France.</E> As used in §§ 514.1 to 514.10, the term “France”, when used in a geographical sense, means continental France, exclusive of Algeria and the Colonies. </P> </SECTION> <SECTION> <SECTNO>§ 514.2</SECTNO> <SUBJECT>Dividends.</SUBJECT> <P> (a) <E T="03">General.</E> (1) The rate of United States tax imposed by the Internal Revenue Code upon dividends derived from sources within the United States on or after January 1, 1952, by a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) who is a resident of France when such dividend is so paid, or by a French corporation, shall not exceed 15 percent if such alien or corporation at no time during the taxable year in which such dividends are so received has no permanent establishment within the United States. Article I(a) of the convention, signed June 22, 1956. As to what constitutes a “permanent establishment” see Protocol III(a), in § 514.1. </P> <P> (2) Thus, if a nonresident alien individual who is a resident of France performs personal services within the United States during the taxable year but has at no time during such year a permanent establishment within the United States, he is entitled to the reduced rate of tax with respect to dividends derived from United States sources, as provided in Article I(d) of the convention even though under the <PRTPAGE P="27"/> provisions of section 871(c) of the Internal Revenue Code of 1954 he has engaged in trade or business within the United States during such year by reason of his having rendered personal services therein. </P> <P> (b) <E T="03">Effect of address in France on withholding in the case of dividends.</E> For the purpose of withholding of United States tax in the case of dividends, every nonresident alien (including a nonresident alien individual, fiduciary, and partnership) whose address is in France shall be deemed by United States withholding agents to be a nonresident alien who is a resident of France not having a permanent establishment in the United States; and every foreign corporation whose address is in France shall be deemed by such withholding agents to be a French corporation not having a permanent establishment in the United States. </P> <P> (c) <E T="03">Rate of withholding.</E> (1) Withholding at source in the case of dividends derived from sources within the United States and paid on or after January 1, 1957, to nonresident aliens (including a nonresident alien individual, fiduciary, and partnership) and to foreign corporations, whose addresses are in France, shall be at the rate of 15 percent in every case except that in which, prior to the date of payment of such dividends, the Commissioner of Internal Revenue has notified the withholding agent that the reduced rate of withholding shall not apply. </P> <P>(2) The preceding provisions respecting the application of the reduced withholding rate in the case of dividends paid to nonresident aliens and foreign corporations with addresses in France are based upon the assumption that the payee of the dividend is the actual owner of the capital stock from which the dividend is derived and consequently is the person liable to the United States upon such dividend. As to action by the recipient who is not the owner of the dividend, see § 514.3.</P> <P> (3) The rate at which the United States tax has been withheld from any dividend paid at any time after the expiration of the thirtieth day after the date on which §§ 514.1 to 514.10 are published in the <E T="04">Federal Register</E> to any person whose address is in France at the time the dividend is paid shall be shown either in writing or by appropriate stamp on the check, draft, or other evidence of payment or on an accompanying statement. </P> </SECTION> <SECTION> <SECTNO>§ 514.3</SECTNO> <SUBJECT>Dividends received by addressee not actual owner.</SUBJECT> <P> (a) <E T="03">Additional tax to be withheld</E> —(1) <E T="03">Nominee or representative.</E> The recipient in France of any dividend, paid on or after January 1, 1957, from which United States tax at the reduced rate of 15 percent has been withheld at source pursuant to § 514.2(c)(1), who is a nominee or representative through whom the dividend is received by a person other than one described in § 514.2(a) as being entitled to the reduced rate, shall withhold an additional amount of United States tax equivalent to the United States tax which would have been withheld if the convention had not been in effect (30 percent as of the date of approval of §§ 514.1 to 514.10) minus the 15 percent which has been withheld at the source. </P> <P> (2) <E T="03">Fiduciary or partnership.</E> A fiduciary or a partnership with an address in France which receives, otherwise than as a nominee or representative, a dividend from which United States tax at the reduced rate of 15 percent has been withheld at source pursuant to § 514.2 shall withhold an additional amount of United States tax from the portion of the dividend included in the gross income from sources within the United States of any beneficiary or partner, as the case may be, who is not entitled to the reduced rate of tax in accordance with § 514.2(c). The amount of the additional tax is to be calculated in the same manner as under subparagraph (1) of this paragraph. </P> <P> (3) <E T="03">Released amounts of tax.</E> If any amount of United States tax is released pursuant to § 514.8(a)(1) by the withholding agent in the United States with respect to a dividend paid to a nominee, representative, fiduciary, or partnership with an address in France, the latter shall withhold from such released amount any additional amount of United States tax, otherwise required to be withheld from the dividend by the provisions of subparagraphs (1) and (2) of this paragraph, in the same manner as if at the time of payment of the dividends United States tax at the <PRTPAGE P="28"/> rate of only 15 percent had been withheld at source therefrom. </P> <P> (b) <E T="03">Returns filed by French withholding agents.</E> The amounts withheld pursuant to paragraph (a) of this section by any withholding agent in France shall be deposited, without converting the amounts into United States dollars, with the Directeur General des Impots of France on or before the 15th day after the close of the quarter of the calendar year in which the withholding in France occurs. The withholding agent making the deposit shall render therewith such appropriate French form as may be prescribed by the Directeur General des Impots. The amounts so deposited should be remitted by the Directeur General des Impots by draft in the United States dollars to the Director, International Operations Division, Internal Revenue Service, Washington 25, D. C., U. S. A., on or before the end of the calendar month in which the deposit is made, and should be accompanied by such French form as may be required to be rendered by the withholding agent in France in connection with the deposit. </P> </SECTION> <SECTION> <SECTNO>§ 514.4</SECTNO> <SUBJECT>Interest.</SUBJECT> <P> (a) <E T="03">General.</E> The rate of United States tax imposed by the Internal Revenue Code upon interest on bonds, securities, notes, debentures, or on any other form of indebtedness, including interest on obligations of the United States, obligations of instrumentalities of the United States, and mortgages and bonds secured by real property, which is derived from sources within the United States in taxable years beginning on or after January 1, 1952, by a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) who is a resident of France, or by a French corporation or other entity, shall not exceed 15 percent under the provisions of Article I(d) of the convention if such alien, corporation, or other French entity at no time during the taxable year in which such interest is received has a permanent establishment in the United States. As to what constitutes a permanent establishment see Article III(a) of the convention. </P> <P> (b) <E T="03">Application of reduced rate at source.</E> (1) To secure withholding of United States tax at the rate of 15 percent at source in the case of coupon bond interest, the nonresident alien who is a resident of France, or the French corporation or other entity, shall, for each issue of bonds, file Form 1001-F in duplicate when presenting the interest coupons for payment. This form shall be signed by the owner of the interest, or by his trustee or agent, and shall show the name and address of the obligor, the name and address of the owner of the interest, and the amount of the interest. It shall contain a statement that the owner (i) is a resident of France, or is a French corporation or other entity, and (ii) has no permanent establishment in the United States. </P> <P>(2) The reduction in the rate of United States tax contemplated by Article 6A of the convention, insofar as it concerns coupon bond interest, is applicable only to the owner of the interest. The person presenting the coupon or on whose behalf it is presented shall, for the purpose of the reduction in tax, be deemed to be the owner of the interest only if he is, at the time the coupon is presented for payment, the owner of the bond from which the coupon has been detached. If the person presenting the coupon, or on whose behalf it is presented, is not the owner of the bond, Form 1001, and not Form 1001-F, shall be executed.</P> <P>(3) The original and duplicate of Form 1001-F shall be forwarded by the withholding agent to the Director, International Operations Division, Internal Revenue Service, Washington 25, D. C., with the annual return on Form 1042. Form 1001-F shall be listed on Form 1042.</P> <P> (4) To secure the reduced rate of United States tax at source in the case of interest other than coupon bond interest, the nonresident alien individual who is a resident of France, or the French corporation or other entity, shall file Form 1001A-F in duplicate with the withholding agent in the United States. This form shall be signed by the owner of the interest, or by his trustee or agent, and shall show the name and address of the obligor and the name and address of the owner of the interest. It shall contain a statement that the owner (i) is a resident of <PRTPAGE P="29"/> France, or is a French corporation or other entity, and (ii) has no permanent establishment in the United States. </P> <P>(5) Form 1001A-F shall be filed with the withholding agent for each successive three-calendar-year period during which such interest is paid. For this purpose, the first such period shall commence with the beginning of the calendar year in which such income is first paid on or after January 1, 1957. Each such form filed with any withholding agent shall be filed not later than 20 days preceding the date of the first payment within each successive period, or, if that is not possible because of special circumstances, as soon as possible after such first payment. Once such a form has been filed in respect of any three-calendar-year period, no additional Form 1001A-F need be filed in respect thereto unless the Commissioner of Internal Revenue notifies the withholding agent that another such form shall be filed by the taxpayer. If, after filing such form, the taxpayer ceases to be eligible for the reduced rate of United States tax granted by Article 6A of the convention in respect to such interest, he shall promptly notify the withholding agent by letter in duplicate. When any change occurs in the ownership of the interest as recorded on the books of the payer, the reduction in rate of withholding of United States tax shall no longer apply unless the new owner of record is entitled to and does properly file a Form 1001A-F with the withholding agent.</P> <P>(6) The duplicate of each Form 1001A-F shall be immediately forwarded by the withholding agent to the Director, International Operations Division, Internal Revenue Service, Washington 25, D. C.</P> </SECTION> <SECTION> <SECTNO>§ 514.5</SECTNO> <SUBJECT>Patent and copyright royalties and film rentals.</SUBJECT> <P> (a) <E T="03">Exemption from tax.</E> Royalties for the right to use copyrights, patents, designs, secret processes and formulae, trademarks, and other analogous property, and royalties and rentals in respect of motion picture films or for the use of industrial, commercial, or scientific equipment, which are derived from sources within the United States on or after January 1, 1945, by a nonresident alien individual who is a resident of France, or by a French corporation, are exempt from United States tax under the provisions of Article 7 of the convention signed July 25, 1939, as modified by Article 7(b) of the convention signed October 18, 1946, if such alien or corporation at no time during the taxable year in which such income is derived has engaged in trade or business within the United States through a permanent establishment situated therein. </P> <P> (b) <E T="03">Exemption from withholding of United States tax.</E> To avoid withholding of United States tax at source in the case of items of income to which this section applies, the nonresident alien who is a resident of France, or the French corporation, shall file Form 1001A-F, in duplicate, with the withholding agent in the United States. </P> <P> (c) <E T="03">Manner of filing.</E> The provisions of § 514.4 relating to the execution, filing, effective period, and disposition of Form 1001A-F, are equally applicable with respect to the income falling within the scope of this section. </P> <P> (d) <E T="03">Revocation of 26 CFR</E> ( <E T="03">1939</E> ) <E T="03">7.418</E> ( <E T="03">Treasury Decision 5499</E> ). Effective January 1, 1957, the provisions of 26 CFR 7.418 (Rev. 1953, Parts 1-79, and Supps.) (Treasury Decision 5499, 11 F.R. 2158), approved February 27, 1946, are hereby made inapplicable, and the provisions of this section are hereby substituted therefor with respect to payments of royalties and film rentals made on or after January 1, 1957. </P> </SECTION> <SECTION> <SECTNO>§ 514.6</SECTNO> <SUBJECT>Private pensions and life annuities.</SUBJECT> <P> (a) <E T="03">Exemption from tax.</E> Private pensions and life annuities as defined in paragraph (d) of this section, derived from sources within the United States on or after January 1, 1945, and paid to a nonresident alien who is a resident of France are exempt from United States tax under the provisions of Article 8 of the convention of July 25, 1939. </P> <P> (b) <E T="03">Exemption from withholding of United States tax—Form to use.</E> To secure exemption from withholding of United States tax at the source in the case of private pensions and life annuities, the nonresident alien who is a resident of France shall file Form <PRTPAGE P="30"/> 1001A-F, in duplicate, with the withholding agent in the United States. </P> <P> (c) <E T="03">Manner of filing.</E> The provisions of § 514.4 relating to the execution, filing, effective period, and disposal of Form 1001A-F are equally applicable with respect to the income falling within the scope of this section. </P> <P> (d) <E T="03">Definition.</E> As used in this section, the term “pensions” means periodic payments made in consideration for services rendered or by way of compensation for injuries received, and the term “life annuities” means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration in money or money's worth. Neither term includes retired pay or pensions paid by the United States or by any State or Territory of the United States. </P> </SECTION> <SECTION> <SECTNO>§ 514.7</SECTNO> <SUBJECT>Beneficiaries of a domestic estate or trust.</SUBJECT> <P> (a) <E T="03">Entitled to benefits of convention.</E> If he otherwise satisfies the requirements of the respective articles concerned, a nonresident alien individual who is a resident of France and who is a beneficiary of a domestic estate or trust shall be entitled to the reduction in the rate of, or exemption from, United States tax granted by Articles 6A and 7 of the convention with respect to dividends, interest, and patent royalties and other like amounts to the extent that (1) any amount paid, credited, or required to be distributed by such estate or trust to such beneficiary is deemed to consist of such items, and (2) such items would, without regard to the convention, be includible in his gross income. </P> <P> (b) <E T="03">Withholding of United States tax.</E> In order to be entitled, because of the application of paragraph (a) of this section, to the reduction in rate of, or exemption from, withholding of United States tax the beneficiary must otherwise satisfy the requirements of the respective articles concerned, and shall, where applicable, execute and submit to the fiduciary of the estate or trust in the United States the appropriate form or forms prescribed in §§ 514.4(b) and 514.6(b). </P> <P> (c) <E T="03">Amounts otherwise includible in gross income of beneficiary.</E> For the determination of amounts which, without regard to the convention, are includible in the gross income of the beneficiary, see subchapter J of chapter 1 of the Internal Revenue Code of 1954, and the regulations thereunder. </P> </SECTION> <SECTION> <SECTNO>§ 514.8</SECTNO> <SUBJECT>Release of excess tax withheld at source.</SUBJECT> <P> (a) <E T="03">Amounts to be released</E> —(1) <E T="03">Dividends derived from domestic corporation.</E> If United States tax has been withheld at the statutory rate on or after January 1, 1957, from dividends described in § 514.2(a) and derived from a domestic corporation by a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) or by a foreign corporation, whose address at the time of payment was in France, the withholding agent shall release and pay over to the person from whom the tax was withheld an amount which is equal to the difference between the tax so withheld and the tax required to be withheld pursuant to § 514.2(c). </P> <P> (2) <E T="03">Coupon bond interest</E> —(i) <E T="03">Substitute form.</E> In the case of every taxpayer who furnishes to the withholding agent Form 1001-F clearly marked “Substitute” and executed in accordance with § 514.4(b)(1), where United States tax has been withheld at the statutory rate on or after January 1, 1957, from coupon bond interest, the withholding agent shall release and pay over to the person from whom the tax was withheld an amount which is equal to the difference between the tax so withheld and the tax required to be withheld pursuant to § 514.4(b)(1) if the taxpayer also attaches to such form a letter in duplicate, signed by the owner, trustee, or agent and containing the following: </P> <P> ( <E T="03">a</E> ) The name and address of the obligor; </P> <P> ( <E T="03">b</E> ) The name and address of the owner from which the excess tax was withheld; </P> <P> ( <E T="03">c</E> ) A statement that, at the time when the interest was derived from which the excess tax was withheld, the owner was neither a citizen nor a resident of the United States but was a resident of France, or, in the case of a corporation, the owner was a French corporation; and <PRTPAGE P="31"/> </P> <P> ( <E T="03">d</E> ) A statement that the owner at no time during the taxable year in which the interest was derived was engaged in trade or business within the United States through a permanent establishment situated therein. </P> <FP>One such substitute form shall be filed, in duplicate, with respect to each issue of bonds and will serve with respect to that issue to replace all Forms 1001 previously filed by the taxpayer in the calendar year in which the excess tax was withheld and with respect to which such excess is released. If the person presenting the coupon, or on whose behalf it is presented, is not the owner of the bond, Form 1001, and not Form 1001-F, shall be executed.</FP> <P> (ii) <E T="03">Disposition of form.</E> The original and duplicate of substitute Form 1001-F (and letter) shall be forwarded by the withholding agent to the Director, International Operations Division, Internal Revenue Service, Washington, D.C., with the annual return on Form 1042. Substitute Form 1001-F need not be listed on Form 1042. </P> <P> (3) <E T="03">Noncoupon interest, royalties, private pensions, and life annuities.</E> (i) If a taxpayer furnishes to the withholding agent a Form 1001A-F, properly executed as prescribed by § 514.4(b)(4), and United States tax has been withheld at the statutory rate on or after January 1, 1957, from noncoupon interest payments in respect of which the form is filed, the withholding agent should release and pay over to the person from whom the tax was withheld an amount which is equal to the difference between the tax so withheld and the tax required to be withheld pursuant to § 514.4(b)(4). </P> <P>(ii) If a taxpayer furnishes to the withholding agent a Form 1001A-F, properly executed as prescribed by § 514.4(b)(4), and United States tax has been withheld at the statutory rate on or after January 1, 1957, from royalties, private pensions, and life annuities in respect of which the form is filed, the withholding agent shall release and pay over to the person from whom the tax was withheld an amount which is equal to the total tax so withheld.</P> <P> (b) <E T="03">Amounts not to be released.</E> The provisions of this section do not apply to excess tax withheld at source which has been paid by the withholding agent to the internal revenue officer entitled to receive payment of the tax withheld under chapter 3 of the Internal Revenue Code of 1954. </P> <P> (c) <E T="03">Statutory rate.</E> As used in this section, the term “statutory rate” means the rate prescribed by chapter 3 of the Internal Revenue Code of 1954 and the regulations thereunder, as though the convention had not come into effect. </P> </SECTION> <SECTION> <SECTNO>§ 514.9</SECTNO> <SUBJECT>Refund of excess tax withheld.</SUBJECT> <P> (a) <E T="03">Years 1952, 1953, 1954, 1955, 1956.</E> Where the tax withheld at the source upon dividends and interest paid in any one or more of the calendar years 1952, 1953, 1954, 1955, and 1956 is in excess of the tax due from the taxpayer under the convention, supplemented as set forth above, it will be necessary for the taxpayer to file an income tax return (Form 1040NB France for individuals and Form 1120NB France for corporations) with respect to such taxable year or years. The return shall cover all years for which a refund is claimed. The return must be filed on or before June 13, 1959. One return shall cover all years for which a refund is claimed. The taxpayer's total fixed or determinable, annual or periodical income (other than royalties) from sources within the United States should be reported on the return, and the income for each taxable year should be shown separately. There shall also be shown on such returns the amounts, if any, received in any of such years of capital gains (other than gains from the sale or exchange of stocks, securities or commodities) from sources within the United States. For this purpose, beginning with the calendar year 1954, certain distributions from employees' trusts, and amounts received incident to disposal of timber or coal or patent rights shall be included in such capital gains. See section 871(a)(1) of the Internal Revenue Code of 1954 for provisions pertaining to individual taxpayers and section 881(a) for provisions pertinent to corporate taxpayers. There shall be included with the return the following statements: </P> <P> (1) That the taxpayer was a nonresident alien (including a nonresident alien individual, fiduciary, or partnership) resident in France or was a <PRTPAGE P="32"/> French corporation, during the year or years for which the return is filed; </P> <P>(2) That the taxpayer had no permanent establishment in the United States during the respective years in which the income was received;</P> <P>(3) That no penalty for fraud has been imposed by the United States against the taxpayer claimant with respect to income tax for the year or years for which the return is filed.</P> <FP>In addition to the above statements, all information requested on the return must be furnished. Any tax paid in excess of that due from the owner of the income will be refunded by the United States Government as required by law. For the purpose of refund of excess tax withheld resulting from the tax convention, a properly executed return on Form 1040NB France or Form 1120NB France shall constitute a claim for refund or credit for the amount of the overpayment disclosed by such return.</FP> <P> (b) <E T="03">Date of payment of tax.</E> The United States tax withheld from dividends and interest derived from sources within the United States by nonresident aliens, or by a foreign corporation not engaged in trade or business in the United States, is deemed to have been paid on March 15 of the calendar year immediately succeeding that in which such income has been so derived. Section 1461, Internal Revenue Code of 1954. Hence, the United States tax withheld from dividends and interest derived by such aliens resident in France and such French corporations for the years 1952, 1953, 1954, 1955, and 1956 is deemed to have been paid, respectively, on March 15, 1953, March 15, 1954, March 15, 1955, March 15, 1956, and March 15, 1957. </P> </SECTION> <SECTION> <SECTNO>§ 514.10</SECTNO> <SUBJECT>Effective date.</SUBJECT> <P>The provisions of §§ 514.1 through 517.9 shall be effective with respect to taxable years beginning after December 31, 1956, and before January 1, 1967, or with respect to dividends, interest, and royalties paid before August 11, 1968.</P> <CITA>[T.D. 6986, 34 FR 136, Jan. 4, 1969]</CITA> </SECTION> <SUBJGRP> <HD SOURCE="HED">Taxable Years Beginning After December 31, 1966, or Dividends, Interest, And Royalties Paid on or After August 11, 1968</HD> <SOURCE> <HD SOURCE="HED">Source:</HD> <P>T.D. 6986, 34 FR 136, Jan. 4, 1969, unless otherwise noted.</P> </SOURCE> <SECTION> <SECTNO>§ 514.22</SECTNO> <SUBJECT>Dividends received by persons not entitled to reduced rate of tax.</SUBJECT> <P> (a) <E T="03">General.</E> Article 27(1) of the convention provides that each Contracting State shall undertake to lend assistance and support to the other Contracting State in the collection of taxes covered by the convention. </P> <P> (b) <E T="03">Additional French tax to be withheld in the United States</E> —(1) <E T="03">By a nominee or representative.</E> The recipient in the United States of any dividend from which French tax has been withheld at the reduced rate of 15 percent, who is a nominee or representative through whom the dividend is received by a person who is not a resident of the United States, shall withhold an additional amount of French tax equivalent to the French tax which would have been withheld if the convention had not been in effect (25 percent as of the date of approval of this Treasury decision) minus the 15 percent which has been withheld at the source. </P> <P> (2) <E T="03">By a fiduciary or partnership.</E> A fiduciary or partnership with an address in the United States which receives, otherwise than as a nominee or representative, a dividend from sources within France from which French tax has been withheld at the reduced rate of 15 percent, shall withhold an additional amount of French tax from the portion of the dividend included in the gross income from sources within France of any beneficiary or partner, as the case may be, who is not entitled to the reduced rate of tax in accordance with the applicable provisions of the convention. The amount of the additional tax is to be calculated in the same manner as under subparagraph (1) of this paragraph. </P> <P> (3) <E T="03">Withholding additional French tax from amounts released or refunded.</E> If any amount of French tax is released by the withholding agent in France with respect to a dividend received by a nominee, representative, fiduciary, or partnership in the United States, the <PRTPAGE P="33"/> recipient shall withhold from such released amount any additional amount of French tax otherwise required to be withheld from the dividend by the provisions of subparagraphs (1) and (2) of this paragraph, in the same manner as if at the time of payment of the dividends French tax at the rate of 15 percent had been withheld therefrom. </P> <P> (4) <E T="03">Return of French tax by U.S. withholding agents.</E> Amounts of French tax withheld pursuant to this paragraph by withholding agents in the United States shall be deposited in U.S. dollars with the Director, Office of International Operations, Internal Revenue Service, Washington, D.C. 20225, on or before the 16th day after the close of the quarter of the calendar year in which the withholding occurs. Such withholding agent shall also submit such appropriate forms as may be prescribed by the Commissioner of Internal Revenue. </P> <CITA>[T.D. 6986, 34 FR 136, Jan. 4, 1969, as amended by T.D. 8734, 62 FR 53498, Oct. 14, 1997]</CITA> </SECTION> </SUBJGRP> </SUBPART> </PART> <PART> <RESERVED>PARTS 515-520 [RESERVED]</RESERVED> </PART> <PART> <EAR>Pt. 521</EAR> <HD SOURCE="HED">PART 521—DENMARK</HD> <CONTENTS> <SUBPART> <HD SOURCE="HED">Subpart—General Income Tax</HD> <SUBJGRP> <HD SOURCE="HED">Taxation of Nonresident Aliens Who Are Residents of Denmark and of Danish Corporations</HD> <SECHD>Sec.</SECHD> <SECTNO>521.101</SECTNO> <SUBJECT>Introductory.</SUBJECT> <SECTNO>521.102</SECTNO> <SUBJECT>Applicable provisions of the Internal Revenue Code.</SUBJECT> <SECTNO>521.103</SECTNO> <SUBJECT>Scope of the convention.</SUBJECT> <SECTNO>521.104</SECTNO> <SUBJECT>Definitions.</SUBJECT> <SECTNO>521.105</SECTNO> <SUBJECT>Scope of convention with respect to determination of “industrial or commercial profits”.</SUBJECT> <SECTNO>521.106</SECTNO> <SUBJECT>Control of a domestic enterprise by a Danish enterprise.</SUBJECT> <SECTNO>521.107</SECTNO> <SUBJECT>Income from operation of ships or aircraft.</SUBJECT> <SECTNO>521.108</SECTNO> <SUBJECT>Exemption from, or reduction in rate of, United States tax in the case of dividends, interest and royalties.</SUBJECT> <SECTNO>521.109</SECTNO> <SUBJECT>Real property income, natural resource royalties.</SUBJECT> <SECTNO>521.110</SECTNO> <SUBJECT>Government wages, salaries, pensions and similar remuneration.</SUBJECT> <SECTNO>521.111</SECTNO> <SUBJECT>Pensions and life annuities.</SUBJECT> <SECTNO>521.112</SECTNO> <SUBJECT>Compensation for labor or personal services.</SUBJECT> <SECTNO>521.113</SECTNO> <SUBJECT>Students and apprentices; remittances.</SUBJECT> <SECTNO>521.114</SECTNO> <SUBJECT>Visiting professors or teachers.</SUBJECT> <SECTNO>521.115</SECTNO> <SUBJECT>Credit against United States tax liability for Danish tax.</SUBJECT> <SECTNO>521.116</SECTNO> <SUBJECT>Reciprocal administrative assistance.</SUBJECT> <SECTNO>521.117</SECTNO> <SUBJECT>Claims in cases of double taxation.</SUBJECT> </SUBJGRP> </SUBPART> </CONTENTS> <AUTH> <HD SOURCE="HED">Authority:</HD> <P>26 U.S.C. 62, 143, 144, 211, and 231.</P> </AUTH> <SUBPART> <HD SOURCE="HED">Subpart—General Income Tax</HD> <SOURCE> <HD SOURCE="HED">Source:</HD> <P>T.D. 5777, 15 FR 1595, Mar. 22, 1950, unless otherwise noted. Redesignated at 25 FR 14022, Dec. 31, 1960.</P> </SOURCE> <SUBJGRP> <HD SOURCE="HED">Taxation of Nonresident Aliens Who Are Residents of Denmark and of Danish Corporations</HD> <SECTION> <SECTNO>§ 521.101</SECTNO> <SUBJECT>Introductory.</SUBJECT> <P>The income tax convention between the United States and the Kingdom of Denmark, signed May 6, 1948, proclaimed (with reservations thereto) by the President of the United States on December 8, 1948, and effective for taxable years beginning on and after January 1, 1948 (referred to in this subpart as the convention), provides in part as follows:</P> <EXTRACT> <HD SOURCE="HD1">Article I</HD> <P>(1) The taxes referred to in this Convention are:</P> <P>(a) In the case of the United States of America: The Federal income tax, including surtaxes.</P> <P>(b) In the case of Denmark:</P> <P>The national income tax, including the war profits tax.</P> <P>The intercommunal income tax.</P> <P>The communal income tax.</P> <P>(2) The present Convention shall also apply to any other taxes of a substantially similar character imposed by either contracting State subsequently to the date of signature of the present Convention.</P> <HD SOURCE="HD1">Article II</HD> <P>(1) As used in this Convention:</P> <P>(a) The term “United States” means the United States of America, and when used in a geographical sense includes only the States, the Territories of Alaska and Hawaii, and the District of Columbia.</P> <P>(b) The term “Denmark” means the Kingdom of Denmark; the provisions of the Convention shall not, however, extend to the Faroe Islands; nor do they apply to Greenland.</P> <P> (c) The term “permanent establishment” means a branch office, factory, warehouse or <PRTPAGE P="34"/> other fixed place of business, but does not include the casual and temporary use of merely storage facilities, nor does it include an agency unless the agent has and exercises a general authority to negotiate and conclude contracts on behalf of an enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. An enterprise of one of the contracting States shall not be deemed to have a permanent establishment in the other State merely because it carries on business dealings in such other State through a bona fide commission agent, broker or custodian acting in the ordinary course of his business as such. The fact that an enterprise of one of the contracting States maintains in the other State a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute such fixed place of business a permanent establishment of such enterprise. The fact that a corporation of one contracting State has a subsidiary corporation which is a corporation of the other State or which is engaged in trade or business in the other State shall not of itself constitute that subsidiary corporation a permanent establishment of its parent corporation. </P> <P>(d) The term “enterprise of one of the contracting States” means, as the case may be, “United States enterprise” or “Danish enterprise”.</P> <P>(e) The term “enterprise” includes every form of undertaking whether carried on by an individual, partnership, corporation, or any other entity.</P> <P>(f) The term “United States enterprise” means an enterprise carried on in the United States of America by a resident of the United States of America or by a United States corporation or other entity; the term “United States corporation or other entity” means a partnership, corporation or other entity created or organized in the United States of America or under the law of the United States of America or of any State or Territory of the United States of America.</P> <P>(g) The term “Danish enterprise” means an enterprise carried on in Denmark by a resident of Denmark or by a Danish corporation or other entity; the term “Danish corporation or other entity” means a partnership, corporation, or other entity created or organized in Denmark or under Danish laws.</P> <P>(h) The term “competent authorities” means, in the case of the United States, the Commissioner of Internal Revenue or his authorized representative; and in the case of Denmark, the Chief of the Taxation Department of the Ministry of Finance (Generaldirektoren for Skattevaesenet) or his authorized representative.</P> <P>(2) In the application of the provisions of the present Convention by one of the contracting States any term not otherwise defined, shall, unless the context otherwise requires, have the meaning which such term has under its own tax laws.</P> <HD SOURCE="HD1">Article III</HD> <P>(1) An enterprise of one of the contracting States shall not be subject to taxation in the other contracting State in respect of its industrial and commercial profits unless it is engaged in trade or business in such other State through a permanent establishment situated therein. If it is so engaged such other State may impose its tax upon the entire income of such enterprise from sources within such other State.</P> <P>(2) In determining the industrial or commercial profits from sources within the territory of one of the contracting States of an enterprise of the other contracting State, no profits shall be deemed to arise from the mere purchase of goods or merchandise within the territory of the former contracting State by such enterprise.</P> <P>(3) Where an enterprise of one of the contracting States is engaged in trade or business in the territory of the other contracting State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits which it might be expected to derive if it were an independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment and the profits so attributed shall, subject to the law of such other contracting State, be deemed to be income from sources within the territory of such other contracting State.</P> <HD SOURCE="HD1">Article IV</HD> <P>Where an enterprise of one of the contracting States, by reason of its participation in the management or the financial structure of an enterprise of the other contracting State, makes with or imposes on the latter, in their commercial or financial relations, conditions different from those which would be made with an independent enterprise, any profits which would normally have accrued to one of the enterprises but by reason of those conditions have not so accrued, may be included in the profits of that enterprise and taxed accordingly.</P> <HD SOURCE="HD1">Article V</HD> <P>(1) Income which an enterprise of one of the contracting States derives from the operation of ships or aircraft registered in that State shall be exempt from taxation in the other contracting State.</P> <P> (2) The present Convention shall not be deemed to affect the arrangement between the United States and Denmark providing for relief from double income taxation on shipping profits, effected by exchanges of <PRTPAGE P="35"/> notes dated May 22, August 9 and 18, October 24, 25, and 28, and December 5 and 6, in the year 1922. </P> <HD SOURCE="HD1">Article VI</HD> <P>(1) Dividends shall be taxable only in the contracting State in which the shareholder is resident or, if the shareholder is a corporation or other entity, in the contracting State in which such corporation or other entity is incorporated or organized.</P> <P>(2) Each of the contracting States reserves, however, the right to collect and retain the tax which, under its revenue laws, is deductible at the source with respect to such dividends, but the tax shall not exceed 15 percent of the amount of dividends derived from sources within such State by a resident, corporation or other entity of the other State, if the recipient has no permanent establishment in the contracting State from which the dividends are derived.</P> <P>(3) It is agreed, however, that the rate of dividend tax at the source shall not exceed five percent if the shareholder is a corporation controlling, directly or indirectly, at least 95 percent of the entire voting power in the corporation paying the dividend, and if not more than 25 percent of the gross income of such paying corporation is derived from interest and dividends, other than interest and dividends received from its own subsidiary corporations. Such reduction of the rate to five percent shall not apply if the relationship of the two corporations has been arranged or is maintained primarily with the intention of securing such reduced rate.</P> <HD SOURCE="HD1">Article VII</HD> <P>Interest on bonds, securities, notes, debentures, or on any other form of indebtedness derived from sources within one of the contracting States by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall be exempt from tax by such former State.</P> <HD SOURCE="HD1">Article VIII</HD> <P>Royalties and other amounts derived as consideration for the right to use copyrights, patents, designs, secret processes and formulas, trade-marks and other like property (including rentals and like payments in respect of motion picture films) derived from sources within one of the contracting States by a resident or corporation or other entity of the other contracting State not having a permanent establishment in the former State shall be exempt from taxation in such former State.</P> <HD SOURCE="HD1">Article IX</HD> <P>(1) Income from real property (not including interest derived from mortgages and bonds secured by real property) and royalties in respect of the operation of mines, quarries, or other natural resources, shall be taxable only in the contracting State in which such property, mines, quarries, or other natural resources are situated.</P> <P>(2) A resident or corporation of one of the contracting States deriving any such income from sources within the other contracting State may, for any taxable year, elect to be subject to the tax of such other contracting State, on a net basis, as if such resident or corporation were engaged in trade or business within such other contracting State through a permanent establishment therein during such taxable year.</P> <HD SOURCE="HD1">Article X</HD> <P>(1) Wages, salaries, and similar compensation and pensions paid by one of the contracting States or by any other public authority within that State to individuals residing in the other State shall be taxable only in the former State.</P> <P>(2) Private pensions and life annuities derived from within one of the contracting States and paid to individuals residing in the other contracting State shall be exempt from taxation in the former State.</P> <P>(3) The term “life annuities” as used herein means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in consideration of a gross sum paid for such obligation.</P> <HD SOURCE="HD1">Article XI</HD> <P>(1) Compensation for labor or personal services, including the practice of the liberal professions, shall be taxable only in the contracting State in which such services are rendered.</P> <P>(2) The provisions of paragraph (1) are, however, subject to the following exceptions:</P> <P>(a) A resident of Denmark shall be exempt from United States tax upon compensation for labor or personal services if he is temporarily present in the United States for a period or periods not exceeding a total of ninety days during the taxable year and the compensation received for such services does not exceed $3,000 in the aggregate. If, however, his compensation is received for labor or personal services performed as an employee of, or under contract with, a resident or corporation or other entity of Denmark, he will be exempt from United States tax if his stay in the United States does not exceed a total of 180 days during the taxable year.</P> <P>(b) The provisions of paragraph (2)(a) of this Article shall apply mutatis mutandis, to a resident of the United States with respect to compensation for personal services otherwise subject to income tax in Denmark.</P> <P> (3) The provisions of this Article shall have no application to the income to which Article X (1) relates. <PRTPAGE P="36"/> </P> <HD SOURCE="HD1">Article XII</HD> <P>Gains derived in one of the contracting States from the sale or exchange of capital assets by a resident or corporation or other entity of the other contracting State shall be exempt from taxation in the former State if such resident or corporation or other entity is not engaged in trade or business in such former State. [This Article deleted by reservation, see President's Proclamation hereinafter.]</P> <HD SOURCE="HD1">Article XIII</HD> <P>Students or apprentices, citizens of one of the contracting States, residing in the other contracting State exclusively for purposes of study or for acquiring business experience, shall not be taxable in the latter State in respect of remittances (other than their own income) received by them from abroad for the purposes of their maintenance or studies.</P> <HD SOURCE="HD1">Article XIV</HD> <P>A professor or teacher, a resident of one of the contracting States, who temporarily visits the territory of the other contracting State for the purpose of teaching for a period not exceeding two years at a university, college, school or other educational institution in the other contracting State, shall be exempted in such other contracting State from tax on his remuneration for such teaching for such period.</P> <HD SOURCE="HD1">Article XV</HD> <P>It is agreed that double taxation shall be avoided in the following manner:</P> <P>(a) The United States in determining the income taxes, including surtaxes, of its citizens, residents or corporations may, regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States as if this convention had not come into effect. The United States shall, however, subject to the provisions of section 131, Internal Revenue Code, deduct from its taxes the amount of Danish taxes specified in Article I of this Convention.</P> <P>(b) Denmark, in determining its taxes specified in Article I of this Convention, may regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income subject to such taxes under the taxation laws of Denmark. Denmark shall, however, deduct from the taxes so calculated the United States tax on income coming within the provisions of Articles III, IX, X (1), XIII and XIV of this Convention and on earned income earned within the United States, but in an amount not exceeding that proportion of the Danish taxes which such income bears to the entire income subject to tax by Denmark. Denmark will also allow as a deduction from its taxes an amount equal to 15 percent (five percent in the case of dividends covered by Article VI (3)) of the gross amount of dividends (reduced by the United States tax applicable to such dividends) from sources within the United States.</P> <HD SOURCE="HD1">Article XVI</HD> <P>(1) The citizens of one of the contracting States shall not, while resident in the other contracting State, be subjected therein to other or more burdensome taxes than are the citizens of such other contracting State residing in its territory. As used in this paragraph:</P> <P>(a) The term “citizens” includes all legal persons, partnerships, and associations created or organized under the laws in the respective contracting States, and</P> <P>(b) The term “taxes” means taxes of every kind or description whether national, Federal, state, provincial or municipal.</P> <P>(2) It is agreed that section 25, paragraph 5, of the Danish law No. 391 of July 12, 1946, prescribing an addition of 50 percent of the capital increment tax on corporations in cases where more than 50 percent of the entire stock capital is owned by a single shareholder residing outside Denmark, shall not be applicable when the shareholder in question is a resident of the United States or a United States corporation or other entity.</P> <HD SOURCE="HD1">Article XVII</HD> <P>The competent authorities of the contracting States shall exchange such information (being information available under the respective taxation laws of the contracting States) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the administration of statutory provisions against tax avoidance in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade secret or trade process.</P> <HD SOURCE="HD1">Article XVIII</HD> <P>(1) The contracting States undertake to lend assistance and support to each other in the collection of the taxes which are the subject of the present Convention, together with interest, costs, and additions to the taxes.</P> <P> (2) In the case of application for enforcement of taxes, revenue claims of each of the contracting States which have been finally determined may be accepted for enforcement by the other contracting State and may be collected in that State in accordance with the laws applicable to the enforcement and collection of its own taxes. <PRTPAGE P="37"/> </P> <P>(3) Any application shall include a certification that under the laws of the State making the application the taxes have been finally determined.</P> <P>(4) The assistance provided for in this Article shall not be accorded with respect to the citizens, corporations, or other entities of the State to which application is made, except as is necessary to insure that the exemption or reduced rate of tax granted under the present Convention to such citizens, corporations, or other entities shall not be enjoyed by persons not entitled to such benefits.</P> <HD SOURCE="HD1">Article XIX</HD> <P>The State to which application is made for information or assistance shall comply as soon as possible with the request addressed to it except that such State may refuse to comply with the request for reasons of public policy or if compliance would involve violation of a trade, business, industrial or professional secret or trade process.</P> <HD SOURCE="HD1">Article XX</HD> <P>Where a taxpayer shows proof that the action of the revenue authorities of the contracting States has resulted in double taxation in his case in respect of any of the taxes to which the present Convention relates, he shall be entitled to lodge a claim with the State of which he is a citizen or, if he is not a citizen of either of the contracting States, with the State of which he is a resident, or, if the taxpayer is a corporation or other entity, with the State in which it is created or organized. Should the claim be upheld, the competent authority of such State may come to an agreement with the competent authority of the other State with a view to equitable avoidance of the double taxation in question.</P> <HD SOURCE="HD1">Article XXI</HD> <P>(1) The provisions of this Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions now enjoyed or which may hereafter be granted to such officers.</P> <P>(2) The provisions of the present Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance accorded by the laws of one of the contracting States in the determination of the tax imposed by such State.</P> <P>(3) Should any difficulty or doubt arise as to the interpretation or application of the present Convention, or its relationship to Conventions between one of the contracting States and any other State, the competent authorities of the contracting States may settle the question by mutual agreement.</P> <HD SOURCE="HD1">Article XXII</HD> <P>The competent authorities of the two contracting States may prescribe regulations necessary to interpret and carry out the provisions of this Convention. With respect to the provisions of this Convention relating to exchange of information and mutual assistance in the collection of taxes, such authorities may, by common agreement, prescribe rules concerning matters of procedure, forms of application and replies thereto, conversion of currency, disposition of amounts collected, minimum amounts subject to collection and related matters.</P> <HD SOURCE="HD1">Article xxiii</HD> <P>(1) The present Convention shall be ratified and the instruments of ratification shall be exchanged at Washington as soon as possible.</P> <P>(2) Upon the exchange of instruments of ratification, the present Convention shall have effect.</P> <P>(a) In the case of United States tax, for the taxable years beginning on or after the first day of January of the year in which such exchange takes place;</P> <P>(b) In the case of Danish tax, for the taxable years beginning on or after the first day of April of the year in which such exchange takes place.</P> <P>(3) The present Convention shall continue effective for a period of five years and indefinitely after that period, but may be terminated by either of the contracting States at the end of the five-year period or at any time thereafter, provided that at least six months' prior notice of termination has been given and, in such event, the present Convention shall cease to be effective.</P> <P>(a) As respects United States tax, for the taxable years beginning on or after the first day of January next following the expiration of the six-month period;</P> <P>(b) As respects Danish tax, for the taxable years beginning on or after the first day of April next following the expiration of the six-month period.</P> <P>Done at Washington, in duplicate, in the English and Danish languages, the two texts having equal authenticity, this 6th day of May 1948.</P> <P>For the President of the United States of America:</P> <P> [ <E T="04">seal</E> ] </P> <NAME> <E T="04">G. C. Marshall.</E> </NAME> <P>For his Majesty the King of Denmark:</P> <P> [ <E T="04">seal</E> ] </P> <NAME> <E T="04">Henrik Kauffman.</E> </NAME> <HD SOURCE="HD1">Proclamation of the President of the United States Dated December 8, 1948</HD> <STARS/> <P> And whereas the Senate of the United States of America, by their resolution of <PRTPAGE P="38"/> June 17, 1948, two-thirds of the Senators present concurring therein, did advise and consent to the ratification of the aforesaid convention subject to a reservation, as follows: </P> <P>The Government of the United States of America does not accept Article XII of the convention relating to gains from the sale or exchange of capital assets.</P> <P>And whereas the text of the aforesaid reservation was communicated by the Government of the United States of America to the Government of Denmark and thereafter the Government of Denmark gave notice of its acceptance of the aforesaid reservation;</P> <P>And whereas the aforesaid convention was duly ratified by the President of the United States of America on November 24, 1948, in pursuance of the aforesaid advice and consent of the Senate and subject to the aforesaid reservation, and the said convention, with the exception of Article XII thereof, was duly ratified on the part of Denmark;</P> <P> And whereas the respective instruments of ratification of the aforesaid convention were duly exchanged at Washington on December 1, 1948, and a protocol of exchange of instruments of ratification, in the English and Danish languages, was signed on that date by the respective Plenipotentiaries of the United States of America and Denmark, the English text of which protocol reads in part: “it is the understanding of both Governments that Article XII of the convention aforesaid shall be deemed to be deleted and of no effect.”; <STARS/> </P> </EXTRACT> </SECTION> <SECTION> <SECTNO>§ 521.102</SECTNO> <SUBJECT>Applicable provisions of the Internal Revenue Code.</SUBJECT> <P>(a) The Internal Revenue Code provides in part as follows:</P> <EXTRACT> <HD SOURCE="HD1">Chapter I—Income Tax</HD> <STARS/> <P> <E T="05">Sec. 22. Gross income.</E> <STARS/> </P> <P> (b) <E T="03">Exclusions from gross income.</E> The following items shall not be included in gross income and shall be exempt from taxation under this chapter: <STARS/> </P> <P> (7) <E T="03">Income exempt under treaty.</E> Income of any kind, to the extent required by any treaty obligation of the United States; <STARS/> </P> <P> <E T="05">Sec. 62. Rules and regulations.</E> The Commissioner, with the approval of the Secretary, shall prescribe and publish all needful rules and regulations for the enforcement of this chapter. </P> </EXTRACT> <P>(b) Pursuant to section 62 of the Internal Revenue Code, other provisions of the internal revenue laws, and to Article XXII of the convention, the following regulations, which are designated as §§ 521.101 to 521.117 are hereby prescribed and all regulations inconsistent herewith are modified accordingly.</P> </SECTION> <SECTION> <SECTNO>§ 521.103</SECTNO> <SUBJECT>Scope of the convention.</SUBJECT> <P>(a) The primary purposes of the convention, to be accomplished on a reciprocal basis, are to avoid double taxation upon major items of income derived from sources in one country by persons resident in, or by corporations of, the other country, and to provide for administrative cooperation between the competent tax authorities of the two countries looking to the avoidance of double taxation and fiscal evasion.</P> <P>(b) The specific classes of income from sources within the United States exempt under the convention from United States tax for taxable years beginning on and after January 1, 1948, are:</P> <P>(1) Industrial and commercial profits of a Danish enterprise having no permanent establishment in the United States (Article III);</P> <P>(2) Income derived by a nonresident alien who is a resident of Denmark, or by a Danish corporation, from the operation of ships or aircraft registered in Denmark (Article V);</P> <P>(3) Interest and royalties (including motion picture film rentals) derived by a nonresident alien who is a resident of Denmark or by a Danish corporation if such alien or corporation has no permanent establishment in the United States (Articles VII and VIII);</P> <P>(4) Compensation and pensions paid by Denmark to aliens for services rendered to Denmark (Article X(1));</P> <P> (5) Private pensions and life annuities derived by nonresident alien individuals residing in Denmark (Article X(2)); <PRTPAGE P="39"/> </P> <P>(6) Compensation, subject to certain limitations, for personal services derived by a nonresident alien who is a resident of Denmark (Article XI);</P> <P>(7) Remittances from sources outside the United States received in the United States by a Danish citizen who is temporarily present in the United States for the purposes of study or for acquiring business experience, such remittances being for the purpose of his maintenance or studies (Article XIII);</P> <P>(8) Remuneration derived from teaching in the United States for a period of not more than two years by a professor or teacher who is a resident of Denmark but who is temporarily present in the United States (Article XIV).</P> <P>(c) The convention also reduces to 15 percent the rate of tax otherwise imposed upon dividends derived by a nonresident alien who is a resident of Denmark, or by a Danish corporation, if such alien or corporation has no permanent establishment in the United States (Article VI).</P> <P>(d) [Reserved]</P> <P>(e) The convention does not affect the liability to United States income taxation of citizens of Denmark who are residents of the United States except that such individuals are entitled to the benefits of Article XV (relating to credit for Danish income tax), and of Article XVI (relating to equality of taxation). Except as provided in Article XV, relating to the credit for income tax, the convention does not affect taxation by the United States of a citizen of the United States or of a domestic corporation, even though such citizen is resident in Denmark and such corporation is engaged in trade or business in Denmark.</P> <CITA>[T.D. 5777, 15 FR 1595, Mar. 22, 1950, as amended by T.D. 8732, 62 FR 53498, Oct. 14, 1997]</CITA> </SECTION> <SECTION> <SECTNO>§ 521.104</SECTNO> <SUBJECT>Definitions.</SUBJECT> <P>(a) As used in §§ 521.101 to 521.117, unless the context otherwise requires, the terms defined in the convention shall have the meanings so assigned to them. Any term used in §§ 521.101 to 521.117, which is not defined in the convention but which is defined in the Internal Revenue Code shall be given the definition contained therein unless the context otherwise requires.</P> <P>(b) As used in §§ 521.101 to 521.117.</P> <P> (1) The term “permanent establishment” means a branch office, factory, warehouse or other fixed place of business, but does not include the casual and temporary use of merely storage facilities. The fact that a Danish corporation has a domestic subsidiary corporation or a foreign subsidiary corporation having a branch in the United States, does not of itself constitute either subsidiary corporation a permanent establishment of the parent Danish enterprise. The fact that a Danish enterprise has business dealings in the United States through a bona fide commission agent, broker, or custodian, acting in the ordinary course of his business as such, or maintains in the United States an office or other fixed place of business used exclusively for the purchase of goods or merchandise, does not mean that such Danish enterprise has a permanent establishment in the United States. If, however, a Danish enterprise carries on business in the United States through an agent who has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or if it has an agent who maintains within the United States a stock of merchandise from which he regularly fills orders on behalf of his principal, then such enterprise shall be deemed to have a permanent establishment in the United States. However, an agent having power to contract on behalf of his principal but only at fixed prices and under conditions determined by the principal does not necessarily constitute a permanent establishment of such principal. The mere fact that an agent (assuming he has no general authority to contract on behalf of his employer or principal) maintains samples or occasionally fills orders from incidental stocks of goods maintained in the United States will not constitute a permanent establishment within the United States. The mere fact that salesmen, employees of a Danish enterprise, promote the sale of their employer's products in the United States or that such enterprise transacts business in the United States by means of mail order activities, does not mean such enterprise has a permanent <PRTPAGE P="40"/> establishment therein. The term “permanent establishment” as used in the convention implies the active conduct therein of a business enterprise. The mere ownership, for example, of timberlands or a warehouse in the United States by a Danish enterprise does not mean that such enterprise has a permanent establishment therein. As to the effect of the maintenance of a permanent establishment within the United States upon exemption from United States tax in the case of interest and royalties and reduction in the rate of United States tax in the case of dividends, see § 521.108. </P> <P>(2) The term “enterprise” means any commercial or industrial undertaking whether conducted by an individual, partnership, corporation, or other entity. It includes such activities as manufacturing, merchandising, mining, processing, and banking. It does not include the rendition of personal services. Hence, a non resident alien who is a resident of Denmark and who renders personal services is not, merely by reason of such services, engaged in an enterprise within the meaning of the convention and his liability to United States tax is not affected by Article III of the convention.</P> <P>(3) The term “Danish enterprise” means an enterprise carried on in Denmark by a resident of Denmark or by a Danish corporation or other entity. The term “Danish corporation or other entity” means a partnership, corporation or other entity created or organized in Denmark or under the laws of Denmark.</P> <P>(4) The term “industrial or commercial profits” means profits arising from industrial, commercial, mercantile, manufacturing, and like activities of a Danish enterprise as defined in this section. Such term does not include rentals, royalties, interest, dividends, fees, compensation for personal services, nor gains derived from the sale or exchange of capital assets. Such enumerated items of income are not governed by the provisions of Article III of the convention.</P> </SECTION> <SECTION> <SECTNO>§ 521.105</SECTNO> <SUBJECT>Scope of convention with respect to determination of “industrial or commercial profits”.</SUBJECT> <P> (a) <E T="03">General.</E> Article III of the convention adopts the principle that an enterprise of one of the contracting States shall not be taxable by the other contracting State upon its industrial or commercial profits unless it has a permanent establishment in the latter State. Hence, a Danish enterprise is subject to United States tax upon its industrial and commercial profits to the extent of such profits from sources within the United States only if it has a permanent establishment within the United States. From the standpoint of Federal income taxation, the article has application only to a Danish enterprise and to the industrial and commercial income thereof from sources within the United States. It has no application for example, to compensation for labor or personal services performed in the United States nor to income derived from real property located in the United States, including rentals and royalties therefrom, nor to gains from the sale or disposition of such property, nor to interest, dividends, royalties, other fixed or determinable annual or periodical income and gains derived from the sale or exchange of capital assets. </P> <P> (b) <E T="03">No United States permanent establishment.</E> A nonresident alien (including a nonresident alien individual, fiduciary and partnership) who is a resident of Denmark or a Danish corporation, carrying on an enterprise in Denmark and having no permanent establishment in the United States, is not for taxable years beginning on or after January 1, 1948, subject to United States income tax upon industrial or commercial profits from sources within the United States. For example, if the Danish enterprise carried on by such alien or corporation sells, in 1948, merchandise, such as silverware, dairy products, or liquors, through a bona fide commission agent or broker in the United States acting in the ordinary course of his business as such agent or broker, the resulting profits are, under the terms of Article III of the convention, exempt from United States income tax. Likewise no permanent establishment exists and no United <PRTPAGE P="41"/> States income tax attaches to such profits if such enterprise, through its sales agents in the United States, secures orders for its products, the sales being made in Denmark. </P> <P> (c) <E T="03">United States permanent establishment.</E> A nonresident alien (including a nonresident alien individual, fiduciary and partnership), who is a resident of Denmark, or a Danish corporation, whether or not carrying on a Danish enterprise, having a permanent establishment in the United States, is subject to tax upon industrial or commercial profits from sources within the United States to the same extent as are nonresident aliens and foreign corporations engaged in trade or business therein. In the determination of the income taxable to such alien or foreign corporation all industrial and commercial profits from sources within the United States shall be deemed to be allocable to the permanent establishment in the United States. Hence, for example, if a Danish enterprise having a permanent establishment in the United States sells in the United States, through a commission agent therein goods produced in Denmark, the resulting profits derived from United States sources from such transactions are allocable to such permanent establishment even though such transactions were carried on independently of such establishment. In determining industrial and commercial profits no account shall be taken of the mere purchase of merchandise within the United States by the Danish enterprise. The industrial or commercial profits of the permanent establishment shall be determined as if the establishment were an independent enterprise engaged in the same or similar activities and dealing at arm's length with the enterprise of which it is a permanent establishment. </P> </SECTION> <SECTION> <SECTNO>§ 521.106</SECTNO> <SUBJECT>Control of a domestic enterprise by a Danish enterprise.</SUBJECT> <P>Article IV of the convention provides, in effect, that if a Danish corporation by reason of its control of a domestic enterprise imposes on such later enterprise conditions different from those which would result from normal business relations between independent enterprises, the accounts between the enterprises may be adjusted so as to ascertain the true net income of each enterprise. The purpose is to place the controlled domestic enterprise on a tax parity with an uncontrolled domestic enterprise by determining, according to the standard of an uncontrolled enterprise, the true net income from the property and business of the controlled enterprise. The basic objective of the article is that if the accounting records do not truly reflect the net income from the property and business of such domestic enterprise the Commissioner of Internal Revenue may intervene and, by making such distributions, apportionments, or allocations as he may deem necessary of gross income or deductions of any item or element affecting net income as between such domestic enterprise and the Danish enterprise by which it is controlled or directed, determine the true net income of the domestic enterprise. The provisions of § 29.45-1 of Regulations 111 (26 CFR 1949 ed. Supps. 29.45-1) [and § 39.45-1 of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)] shall, insofar as applicable, be followed in the determination of the net income of the domestic business.</P> </SECTION> <SECTION> <SECTNO>§ 521.107</SECTNO> <SUBJECT>Income from operation of ships or aircraft.</SUBJECT> <P>The income derived from the operation of ships or aircraft registered in Denmark by a nonresident alien who is a resident of Denmark, or by a Danish corporation, and carrying on an enterprise in Denmark, is, for taxable years beginning on or after January 1, 1948, exempt from United States income tax under the provisions of Article V of the convention.</P> </SECTION> <SECTION> <SECTNO>§ 521.108</SECTNO> <SUBJECT>Exemption from, or reduction in rate of, United States tax in the case of dividends, interest and royalties.</SUBJECT> <P> (a) <E T="03">Dividends</E> —(1) <E T="03">General.</E> The tax imposed by the Internal Revenue Code in the case of dividends received from sources within the United States by (i) a nonresident alien (including a nonresident alien individual, fiduciary and partnership) who is a resident of Denmark, or (ii) a Danish corporation is, for taxable years beginning on and <PRTPAGE P="42"/> after January 1, 1948, limited to 15 percent under the provisions of Article VI (relating to dividends) if such alien or corporation, at no time during the taxable year in which such dividends were so derived, had a permanent establishment within the United States. Thus, if a nonresident alien who is a resident of Denmark, performs personal services within the United States during the calendar year 1948 but has at no time during such year a permanent establishment within the United States, he is entitled to the reduced rate of tax with respect to such dividends derived in that year from United States sources, as provided in Article VI of the convention, even though by reason of his having rendered personal services within the United States he is engaged in trade or business therein in that year within the meaning of section 211(b) of the Internal Revenue Code. If, for example, A, a nonresident alien who is a resident of Denmark, derives in 1948, $5,000 compensation for such personal services and his only other income from sources within the United States consists of dividends, the dividends are subject to tax at a rate not to exceed 15 percent and his earned income is subject to normal tax and surtax without taking the dividends into account in determining the tax on such earned income. </P> <P> (2) <E T="03">Dividends paid by a United States subsidiary corporation.</E> Under the provisions of Article VI(3) of the convention, dividends paid by a domestic corporation to a Danish corporation are subject to tax at the rate of only 5 percent if (i) such Danish corporation controls, directly or indirectly, at the time the dividend is paid 95 percent or more of the voting power in such domestic corporation, (ii) not more than 25 percent of the gross income of the domestic corporation for the three-year period immediately preceding the taxable year in which the dividend is paid consists of dividends and interest (other than dividends and interest paid to such domestic corporation by its own subsidiary corporations, if any), and (iii) the relationship between such domestic corporation and such Danish corporation has not been arranged or maintained primarily with the intention of securing such reduced rate of 5 percent. </P> <P> (b) <E T="03">Interest and royalties.</E> (1) Interest, whether on bonds, securities, notes, debentures, or any other form of indebtedness (including interest on obligations of the United States and on obligations of instrumentalities of the United States), and royalties for the right to use copyrights, patents, designs, secret processes and formulae, trade-marks, and other analogous property and royalties (including rentals and like payments in respect of motion picture films) received from sources within the United States by (i) a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) who is a resident of Denmark, or (ii) a Danish corporation, are, for taxable years beginning on and after January 1, 1948, exempt from United States tax under the provisions of Articles VII and VIII of the convention if such alien or corporation at no time during the taxable year in which such interest or royalty was so derived had a permanent establishment situated within the United States. </P> <P>(2) Such interest and royalties are, therefore, not subject to the withholding provisions of the Internal Revenue Code.</P> <P> (c) <E T="03">Beneficiaries of an estate or trust.</E> (1) A nonresident alien who is a resident of Denmark and who is a beneficiary of a domestic estate or trust shall be entitled to the exemption, or reduction in the rate of tax, as the case may be, provided in Articles VI, VII and VIII of the convention with respect to dividends, interest and royalties to the extent that such item or items are included in his distributive share of income of such estate or trust if he at no time during the taxable year had a permanent establishment in the United States. In such case such beneficiary must, in order to be entitled to the exemption or reduction in the rate of tax execute Form 101-D or Form 1001A-D (modified to show dividends where applicable) and file such form with the fiduciary of such estate or trust in the United States. </P> <P> (2) In any case in which dividends, interest or royalties are derived from United States sources by a Danish estate or trust, any beneficiary of such <PRTPAGE P="43"/> estate or trust who is not a resident of Denmark, or who has a permanent establishment in the United States, is not entitled to any exemption under the convention with respect to such income included in his distributive share of the income of the estate or trust. </P> </SECTION> <SECTION> <SECTNO>§ 521.109</SECTNO> <SUBJECT>Real property income, natural resource royalties.</SUBJECT> <P>Under Article IX of the convention, a nonresident alien (including a nonresident alien individual, fiduciary, and partnership) who is a resident of Denmark, or a Danish corporation, who derives from sources within the United States in any taxable year beginning on or after January 1, 1948, income from real property (not including interest derived from mortgages or bonds secured by real property) or royalties from the operation of mines, quarries, oil wells or other natural resources may, for such taxable year, elect to be subject to Federal income tax as if such alien or corporation were engaged in trade or business within the United States by reason of having a permanent establishment therein during such taxable year. Such election shall be made by so signifying on the return for such year. The election so signified shall be irrevocable for the taxable year for which such election is made. In such case a return may be filed by the nonresident alien or foreign corporation even though the sole income of such alien or corporation from sources within the United States is fixed or determinable annual or periodical income upon which the tax has been fully satisfied at the source and there exists no necessity for the filing of the return except for the purposes of securing the benefits of Article IX of the convention. See § 29.217-2 of Regulations 111 (26 CFR 1949 ed. Supps. 29.217-2) [and § 39.217-2 of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)]</P> </SECTION> <SECTION> <SECTNO>§ 521.110</SECTNO> <SUBJECT>Government wages, salaries, pensions and similar remuneration.</SUBJECT> <P>Under Article X (1) of the convention any wage, salary, similar compensation or pension paid by the Government of Denmark or by any other public authority within Denmark to an individual in the United States is exempt from Federal income tax for taxable years beginning on and after January 1, 1948. By reason, however, of the application of Article XV (a) of the convention, such exemption does not apply to recipients of such income who are either citizens of the United States or alien residents therein. As to the taxation generally of compensation of alien employees of foreign governments, see section 116(h) of the Internal Revenue Code and § 29.116-2 of Regulations 111 (26 CFR 1949 ed. Supps. 29.116-2) [and § 39.116-2 of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)].</P> </SECTION> <SECTION> <SECTNO>§ 521.111</SECTNO> <SUBJECT>Pensions and life annuities.</SUBJECT> <P>Under the provisions of Article X(2) of the convention, private pensions and life annuities derived from sources within the United States by nonresident alien individuals who are residents of Denmark are exempt from Federal income tax for taxable years beginning on and after January 1, 1948. The term “life annuities” is defined in Article X(3). The term “private pensions” does not include pensions or retired pay paid by the United States or by any State or Territory of the United States; it does include periodic payments made in consideration for services rendered or by way of compensation for injuries received.</P> </SECTION> <SECTION> <SECTNO>§ 521.112</SECTNO> <SUBJECT>Compensation for labor or personal services.</SUBJECT> <P>Article XI of the convention adopts the principle that compensation for labor or personal services, including the practice of the liberal professions, is subject to tax only in the contracting State in which such services are rendered. Hence, in general, such compensation derived by a nonresident alien individual residing in Denmark for services rendered in the United States is subject to Federal income tax. Under Article XI of the convention this general rule is subject to the following exceptions:</P> <P> (a) Where such individual is temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year, compensation received for labor or personal services within the United States during such year is exempt from <PRTPAGE P="44"/> Federal income tax provided such compensation does not exceed $3,000 in the aggregate. </P> <P>(b) Where such individual is temporarily present in the United States for a period or periods not exceeding a total of 180 days during the taxable year, compensation for labor or personal services within the United States during such year is exempt from Federal income tax provided such compensation is received for services performed as a worker or employee of, or under contract with, a resident or corporation of Denmark (even though such resident or corporation is engaged in trade or business in the United States) which resident or corporation actually bears the expense of such compensation and is not reimbursed therefor by another person.</P> <P>As to the source of compensation for labor or personal services, see section 119(a)(3) of the Internal Revenue Code.</P> </SECTION> <SECTION> <SECTNO>§ 521.113</SECTNO> <SUBJECT>Students and apprentices; remittances.</SUBJECT> <P>Under Article XIII of the convention, citizens of Denmark who are temporarily present in the United States as students or apprentices exclusively for the purposes of study or for acquiring business experience, are exempt for taxable years beginning on or after January 1, 1948, from Federal income tax upon amounts representing remittances from sources outside the United States for the purposes of their maintenance or studies.</P> </SECTION> <SECTION> <SECTNO>§ 521.114</SECTNO> <SUBJECT>Visiting professors or teachers.</SUBJECT> <P>Under Article XIV of the convention, an alien who is a resident of Denmark but who is temporarily present within the United States for the purpose of teaching, lecturing, or instructing at any university, college, school, or other educational institution, situated within the United States, is, for a period not exceeding two years from the date of his arrival in the United States, exempt for taxable years beginning on or after January 1, 1948, from Federal income tax on remuneration received for such services. It shall be deemed that such alien coming to the United States for the purposes indicated has, for a period of not more than two years immediately succeeding the date of his arrival within the United States for such purposes, the tax status of a nonresident alien in the absence of proof of his intention to remain indefinitely in the United States.</P> </SECTION> <SECTION> <SECTNO>§ 521.115</SECTNO> <SUBJECT>Credit against United States tax liability for Danish tax.</SUBJECT> <P>For the purpose of avoidance of double taxation, Article XV provides that, on the part of the United States, there shall be allowed against the United States income tax a credit for the amount of Danish taxes described in Article I of the convention imposed on income derived from sources within Denmark for taxable years beginning on and after January 1, 1948. Such credit, however, is subject to the limitations provided in section 131 of the Internal Revenue Code (relating to the credit for foreign taxes). See §§ 29.131-1 to 29.131-10 of Regulations 111 (26 CFR 1949 ed. Supps. 29.131-1 to 29.131-10) [and §§ 39.131(a) 1 to 39.131(j)-1 of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)].</P> </SECTION> <SECTION> <SECTNO>§ 521.116</SECTNO> <SUBJECT>Reciprocal administrative assistance.</SUBJECT> <P> (a) <E T="03">General.</E> (1) By Article XVII of the convention, the United States and Denmark adopt the principle of exchange of such information as is necessary for carrying out the provisions of the convention or for the prevention of fraud or for the detection of practices which are aimed at reduction of the revenues of either country, but not including information which would disclose a trade, business, industrial or professional secret or trade process. </P> <P>(2) The information and correspondence relative to exchange of information may be transmitted directly by the Commissioner of Internal Revenue to the Chief of the Taxation Department of the Ministry of Finance (Generaldirektoren for Skattevaesenet) of Denmark.</P> <P> (b) <E T="03">Information to be furnished in due course.</E> (1) Pursuant to such principle, withholding agents shall, in the preparation of withholding returns, Form 1042, report on such returns, for the calendar year 1949 and each subsequent calendar year, in addition to the items of income upon which tax has been <PRTPAGE P="45"/> withheld at the source, those items of income paid to a nonresident alien individual resident in Denmark, or to a Danish corporation, upon which tax has not been withheld at the source. Such return shall show the same information with respect to such items of income upon which tax has not been withheld at the source as is shown with respect to items of income upon which the tax has been withheld at the source. </P> <P>(2) In accordance with the provisions of Article XVII of the convention, the Commissioner of Internal Revenue will transmit to the Chief of the Taxation Department of the Ministry of Finance of Denmark, as soon as practicable after the close of the calendar year 1949, and of each calendar year thereafter during which the convention is in effect, the following information relating to such calendar year: The names and addresses of all persons whose addresses are in Denmark as disclosed on such withholding return, Form 1042, deriving from sources within the United States dividends interest (other than coupon bond interest), rents, royalties, salaries, wages, pensions, annuities and other fixed or determinable annual or periodical profits or income, and the amount of such income with respect to such persons as disclosed on such return, together with ownership certificate, Form 1001-D, filed in connection with coupon bond interest. Such transmission shall constitute compliance with Article XVII of the convention and of §§ 521.101 to 521.117.</P> <P> (c) <E T="03">Information in specific cases.</E> Under the provisions and limitations of Article XVII of the convention, and subject to the provisions of Article XIX and Article XXII of the convention, and upon the request of the Chief of the Taxation Department of the Ministry of Finance of Denmark, the Commissioner of Internal Revenue shall furnish to the Chief of the Taxation Department information available to or obtainable by the Commissioner of Internal Revenue relative to the tax liability of any person under the revenue laws of Denmark in any case in which such information is necessary to the administration of the provisions of the convention or for the prevention of fraud or the administration of statutory provisions against tax avoidance. </P> </SECTION> <SECTION> <SECTNO>§ 521.117</SECTNO> <SUBJECT>Claims in cases of double taxation.</SUBJECT> <P>Under Article XX of the convention, where the action of the revenue authorities of the contracting States has resulted in double taxation in respect of any of the taxes to which the convention relates, the taxpayer is entitled to lodge a claim with the country of which he is a citizen or, if he is not a citizen of either country, with the country of which he is a resident, or if the taxpayer is a corporation or other entity, with the country in which it is created or organized. Article XX further provides that should the claim be upheld, the competent authority of the country with which the claim is lodged may come to an agreement with the competent authority of the other country with a view to equitable avoidance of the double taxation. Such a claim on behalf of a United States citizen or corporation or other entity, or on behalf of a resident of the United States who is not a Danish citizen, shall be filed with the Commissioner of Internal Revenue, Washington, D.C. The claim should be set up in the form of a letter and should show fully all facts on the basis of which the claimant alleges that such double taxation has resulted. If the Commissioner of Internal Revenue determines that there is an appropriate basis for the claim under the convention, he will take the matter up with the Chief of the Taxation Department of the Ministry of Finance of Denmark with a view to arranging an agreement of the character contemplated by Article XX.</P> </SECTION> </SUBJGRP> </SUBPART> </PART> <PART> <RESERVED>PARTS 522-599 [RESERVED]</RESERVED> </PART> </SUBCHAP> </CHAPTER> FINDING AIDS

A list of CFR titles, subtitles, chapters, subchapters and parts and an alphabetical list of agencies publishing in the CFR are included in the CFR Index and Finding Aids volume to the Code of Federal Regulations which is published separately and revised annually.

Table of CFR Titles and Chapters

Alphabetical List of Agencies Appearing in the CFR

Table of OMB Control Numbers

List of CFR Sections Affected

 Chap. Table of CFR Titles and Chapters (Revised as of April 1, 2020) Title 1—General Provisions I Administrative Committee of the Federal Register (Parts 1—49) II Office of the Federal Register (Parts 50—299) III Administrative Conference of the United States (Parts 300—399) IV Miscellaneous Agencies (Parts 400—599) VI National Capital Planning Commission (Parts 600—699) Title 2—Grants and Agreements Subtitle A—Office of Management and Budget Guidance for Grants and Agreements I Office of Management and Budget Governmentwide Guidance for Grants and Agreements (Parts 2—199) II Office of Management and Budget Guidance (Parts 200—299) Subtitle B—Federal Agency Regulations for Grants and Agreements III Department of Health and Human Services (Parts 300—399) IV Department of Agriculture (Parts 400—499) VI Department of State (Parts 600—699) VII Agency for International Development (Parts 700—799) VIII Department of Veterans Affairs (Parts 800—899) IX Department of Energy (Parts 900—999) X Department of the Treasury (Parts 1000—1099) XI Department of Defense (Parts 1100—1199) XII Department of Transportation (Parts 1200—1299) XIII Department of Commerce (Parts 1300—1399) XIV Department of the Interior (Parts 1400—1499) XV Environmental Protection Agency (Parts 1500—1599) XVIII National Aeronautics and Space Administration (Parts 1800—1899) XX United States Nuclear Regulatory Commission (Parts 2000—2099) XXII Corporation for National and Community Service (Parts 2200—2299) XXIII Social Security Administration (Parts 2300—2399) XXIV Department of Housing and Urban Development (Parts 2400—2499) XXV National Science Foundation (Parts 2500—2599) XXVI National Archives and Records Administration (Parts 2600—2699) XXVII Small Business Administration (Parts 2700—2799) XXVIII Department of Justice (Parts 2800—2899) XXIX Department of Labor (Parts 2900—2999) XXX Department of Homeland Security (Parts 3000—3099) XXXI Institute of Museum and Library Services (Parts 3100—3199) XXXII National Endowment for the Arts (Parts 3200—3299) XXXIII National Endowment for the Humanities (Parts 3300—3399) XXXIV Department of Education (Parts 3400—3499) XXXV Export-Import Bank of the United States (Parts 3500—3599) XXXVI Office of National Drug Control Policy, Executive Office of the President (Parts 3600—3699) XXXVII Peace Corps (Parts 3700—3799) LVIII Election Assistance Commission (Parts 5800—5899) LIX Gulf Coast Ecosystem Restoration Council (Parts 5900—5999) Title 3—The President I Executive Office of the President (Parts 100—199) Title 4—Accounts I Government Accountability Office (Parts 1—199) Title 5—Administrative Personnel I Office of Personnel Management (Parts 1—1199) II Merit Systems Protection Board (Parts 1200—1299) III Office of Management and Budget (Parts 1300—1399) IV Office of Personnel Management and Office of the Director of National Intelligence (Parts 1400—1499) V The International Organizations Employees Loyalty Board (Parts 1500—1599) VI Federal Retirement Thrift Investment Board (Parts 1600—1699) VIII Office of Special Counsel (Parts 1800—1899) IX Appalachian Regional Commission (Parts 1900—1999) XI Armed Forces Retirement Home (Parts 2100—2199) XIV Federal Labor Relations Authority, General Counsel of the Federal Labor Relations Authority and Federal Service Impasses Panel (Parts 2400—2499) XVI Office of Government Ethics (Parts 2600—2699) XXI Department of the Treasury (Parts 3100—3199) XXII Federal Deposit Insurance Corporation (Parts 3200—3299) XXIII Department of Energy (Parts 3300—3399) XXIV Federal Energy Regulatory Commission (Parts 3400—3499) XXV Department of the Interior (Parts 3500—3599) XXVI Department of Defense (Parts 3600—3699) XXVIII Department of Justice (Parts 3800—3899) XXIX Federal Communications Commission (Parts 3900—3999) XXX Farm Credit System Insurance Corporation (Parts 4000—4099) XXXI Farm Credit Administration (Parts 4100—4199) XXXIII U.S. International Development Finance Corporation (Parts 4300—4399) XXXIV Securities and Exchange Commission (Parts 4400—4499) XXXV Office of Personnel Management (Parts 4500—4599) XXXVI Department of Homeland Security (Parts 4600—4699) XXXVII Federal Election Commission (Parts 4700—4799) XL Interstate Commerce Commission (Parts 5000—5099) XLI Commodity Futures Trading Commission (Parts 5100—5199) XLII Department of Labor (Parts 5200—5299) XLIII National Science Foundation (Parts 5300—5399) XLV Department of Health and Human Services (Parts 5500—5599) XLVI Postal Rate Commission (Parts 5600—5699) XLVII Federal Trade Commission (Parts 5700—5799) XLVIII Nuclear Regulatory Commission (Parts 5800—5899) XLIX Federal Labor Relations Authority (Parts 5900—5999) L Department of Transportation (Parts 6000—6099) LII Export-Import Bank of the United States (Parts 6200—6299) LIII Department of Education (Parts 6300—6399) LIV Environmental Protection Agency (Parts 6400—6499) LV National Endowment for the Arts (Parts 6500—6599) LVI National Endowment for the Humanities (Parts 6600—6699) LVII General Services Administration (Parts 6700—6799) LVIII Board of Governors of the Federal Reserve System (Parts 6800—6899) LIX National Aeronautics and Space Administration (Parts 6900—6999) LX United States Postal Service (Parts 7000—7099) LXI National Labor Relations Board (Parts 7100—7199) LXII Equal Employment Opportunity Commission (Parts 7200—7299) LXIII Inter-American Foundation (Parts 7300—7399) LXIV Merit Systems Protection Board (Parts 7400—7499) LXV Department of Housing and Urban Development (Parts 7500—7599) LXVI National Archives and Records Administration (Parts 7600—7699) LXVII Institute of Museum and Library Services (Parts 7700—7799) LXVIII Commission on Civil Rights (Parts 7800—7899) LXIX Tennessee Valley Authority (Parts 7900—7999) LXX Court Services and Offender Supervision Agency for the District of Columbia (Parts 8000—8099) LXXI Consumer Product Safety Commission (Parts 8100—8199) LXXIII Department of Agriculture (Parts 8300—8399) LXXIV Federal Mine Safety and Health Review Commission (Parts 8400—8499) LXXVI Federal Retirement Thrift Investment Board (Parts 8600—8699) LXXVII Office of Management and Budget (Parts 8700—8799) LXXX Federal Housing Finance Agency (Parts 9000—9099) LXXXIII Special Inspector General for Afghanistan Reconstruction (Parts 9300—9399) LXXXIV Bureau of Consumer Financial Protection (Parts 9400—9499) LXXXVI National Credit Union Administration (Parts 9600—9699) XCVII Department of Homeland Security Human Resources Management System (Department of Homeland Security—Office of Personnel Management) (Parts 9700—9799) XCVIII Council of the Inspectors General on Integrity and Efficiency (Parts 9800—9899) XCIX Military Compensation and Retirement Modernization Commission (Parts 9900—9999) C National Council on Disability (Parts 10000—10049) CI National Mediation Board (Part 10101) Title 6—Domestic Security I Department of Homeland Security, Office of the Secretary (Parts 1—199) X Privacy and Civil Liberties Oversight Board (Parts 1000—1099) Title 7—Agriculture Subtitle A—Office of the Secretary of Agriculture (Parts 0—26) Subtitle B—Regulations of the Department of Agriculture I Agricultural Marketing Service (Standards, Inspections, Marketing Practices), Department of Agriculture (Parts 27—209) II Food and Nutrition Service, Department of Agriculture (Parts 210—299) III Animal and Plant Health Inspection Service, Department of Agriculture (Parts 300—399) IV Federal Crop Insurance Corporation, Department of Agriculture (Parts 400—499) V Agricultural Research Service, Department of Agriculture (Parts 500—599) VI Natural Resources Conservation Service, Department of Agriculture (Parts 600—699) VII Farm Service Agency, Department of Agriculture (Parts 700—799) VIII Agricultural Marketing Service (Federal Grain Inspection Service, Fair Trade Practices Program), Department of Agriculture (Parts 800—899) IX Agricultural Marketing Service (Marketing Agreements and Orders; Fruits, Vegetables, Nuts), Department of Agriculture (Parts 900—999) X Agricultural Marketing Service (Marketing Agreements and Orders; Milk), Department of Agriculture (Parts 1000—1199) XI Agricultural Marketing Service (Marketing Agreements and Orders; Miscellaneous Commodities), Department of Agriculture (Parts 1200—1299) XIV Commodity Credit Corporation, Department of Agriculture (Parts 1400—1499) XV Foreign Agricultural Service, Department of Agriculture (Parts 1500—1599) XVI [Reserved] XVII Rural Utilities Service, Department of Agriculture (Parts 1700—1799) XVIII Rural Housing Service, Rural Business-Cooperative Service, Rural Utilities Service, and Farm Service Agency, Department of Agriculture (Parts 1800—2099) XX [Reserved] XXV Office of Advocacy and Outreach, Department of Agriculture (Parts 2500—2599) XXVI Office of Inspector General, Department of Agriculture (Parts 2600—2699) XXVII Office of Information Resources Management, Department of Agriculture (Parts 2700—2799) XXVIII Office of Operations, Department of Agriculture (Parts 2800—2899) XXIX Office of Energy Policy and New Uses, Department of Agriculture (Parts 2900—2999) XXX Office of the Chief Financial Officer, Department of Agriculture (Parts 3000—3099) XXXI Office of Environmental Quality, Department of Agriculture (Parts 3100—3199) XXXII Office of Procurement and Property Management, Department of Agriculture (Parts 3200—3299) XXXIII Office of Transportation, Department of Agriculture (Parts 3300—3399) XXXIV National Institute of Food and Agriculture (Parts 3400—3499) XXXV Rural Housing Service, Department of Agriculture (Parts 3500—3599) XXXVI National Agricultural Statistics Service, Department of Agriculture (Parts 3600—3699) XXXVII Economic Research Service, Department of Agriculture (Parts 3700—3799) XXXVIII World Agricultural Outlook Board, Department of Agriculture (Parts 3800—3899) XLI [Reserved] XLII Rural Business-Cooperative Service and Rural Utilities Service, Department of Agriculture (Parts 4200—4299) Title 8—Aliens and Nationality I Department of Homeland Security (Parts 1—499) V Executive Office for Immigration Review, Department of Justice (Parts 1000—1399) Title 9—Animals and Animal Products I Animal and Plant Health Inspection Service, Department of Agriculture (Parts 1—199) II Agricultural Marketing Service (Federal Grain Inspection Service, Fair Trade Practices Program), Department of Agriculture (Parts 200—299) III Food Safety and Inspection Service, Department of Agriculture (Parts 300—599) Title 10—Energy I Nuclear Regulatory Commission (Parts 0—199) II Department of Energy (Parts 200—699) III Department of Energy (Parts 700—999) X Department of Energy (General Provisions) (Parts 1000—1099) XIII Nuclear Waste Technical Review Board (Parts 1300—1399) XVII Defense Nuclear Facilities Safety Board (Parts 1700—1799) XVIII Northeast Interstate Low-Level Radioactive Waste Commission (Parts 1800—1899) Title 11—Federal Elections I Federal Election Commission (Parts 1—9099) II Election Assistance Commission (Parts 9400—9499) Title 12—Banks and Banking I Comptroller of the Currency, Department of the Treasury (Parts 1—199) II Federal Reserve System (Parts 200—299) III Federal Deposit Insurance Corporation (Parts 300—399) IV Export-Import Bank of the United States (Parts 400—499) V (Parts 500—599) [Reserved] VI Farm Credit Administration (Parts 600—699) VII National Credit Union Administration (Parts 700—799) VIII Federal Financing Bank (Parts 800—899) IX Federal Housing Finance Board (Parts 900—999) X Bureau of Consumer Financial Protection (Parts 1000—1099) XI Federal Financial Institutions Examination Council (Parts 1100—1199) XII Federal Housing Finance Agency (Parts 1200—1299) XIII Financial Stability Oversight Council (Parts 1300—1399) XIV Farm Credit System Insurance Corporation (Parts 1400—1499) XV Department of the Treasury (Parts 1500—1599) XVI Office of Financial Research (Parts 1600—1699) XVII Office of Federal Housing Enterprise Oversight, Department of Housing and Urban Development (Parts 1700—1799) XVIII Community Development Financial Institutions Fund, Department of the Treasury (Parts 1800—1899) Title 13—Business Credit and Assistance I Small Business Administration (Parts 1—199) III Economic Development Administration, Department of Commerce (Parts 300—399) IV Emergency Steel Guarantee Loan Board (Parts 400—499) V Emergency Oil and Gas Guaranteed Loan Board (Parts 500—599) Title 14—Aeronautics and Space I Federal Aviation Administration, Department of Transportation (Parts 1—199) II Office of the Secretary, Department of Transportation (Aviation Proceedings) (Parts 200—399) III Commercial Space Transportation, Federal Aviation Administration, Department of Transportation (Parts 400—1199) V National Aeronautics and Space Administration (Parts 1200—1299) VI Air Transportation System Stabilization (Parts 1300—1399) Title 15—Commerce and Foreign Trade Subtitle A—Office of the Secretary of Commerce (Parts 0—29) Subtitle B—Regulations Relating to Commerce and Foreign Trade I Bureau of the Census, Department of Commerce (Parts 30—199) II National Institute of Standards and Technology, Department of Commerce (Parts 200—299) III International Trade Administration, Department of Commerce (Parts 300—399) IV Foreign-Trade Zones Board, Department of Commerce (Parts 400—499) VII Bureau of Industry and Security, Department of Commerce (Parts 700—799) VIII Bureau of Economic Analysis, Department of Commerce (Parts 800—899) IX National Oceanic and Atmospheric Administration, Department of Commerce (Parts 900—999) XI National Technical Information Service, Department of Commerce (Parts 1100—1199) XIII East-West Foreign Trade Board (Parts 1300—1399) XIV Minority Business Development Agency (Parts 1400—1499) Subtitle C—Regulations Relating to Foreign Trade Agreements XX Office of the United States Trade Representative (Parts 2000—2099) Subtitle D—Regulations Relating to Telecommunications and Information XXIII National Telecommunications and Information Administration, Department of Commerce (Parts 2300—2399) [Reserved] Title 16—Commercial Practices I Federal Trade Commission (Parts 0—999) II Consumer Product Safety Commission (Parts 1000—1799) Title 17—Commodity and Securities Exchanges I Commodity Futures Trading Commission (Parts 1—199) II Securities and Exchange Commission (Parts 200—399) IV Department of the Treasury (Parts 400—499) Title 18—Conservation of Power and Water Resources I Federal Energy Regulatory Commission, Department of Energy (Parts 1—399) III Delaware River Basin Commission (Parts 400—499) VI Water Resources Council (Parts 700—799) VIII Susquehanna River Basin Commission (Parts 800—899) XIII Tennessee Valley Authority (Parts 1300—1399) Title 19—Customs Duties I U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury (Parts 0—199) II United States International Trade Commission (Parts 200—299) III International Trade Administration, Department of Commerce (Parts 300—399) IV U.S. Immigration and Customs Enforcement, Department of Homeland Security (Parts 400—599) [Reserved] Title 20—Employees' Benefits I Office of Workers' Compensation Programs, Department of Labor (Parts 1—199) II Railroad Retirement Board (Parts 200—399) III Social Security Administration (Parts 400—499) IV Employees' Compensation Appeals Board, Department of Labor (Parts 500—599) V Employment and Training Administration, Department of Labor (Parts 600—699) VI Office of Workers' Compensation Programs, Department of Labor (Parts 700—799) VII Benefits Review Board, Department of Labor (Parts 800—899) VIII Joint Board for the Enrollment of Actuaries (Parts 900—999) IX Office of the Assistant Secretary for Veterans' Employment and Training Service, Department of Labor (Parts 1000—1099) Title 21—Food and Drugs I Food and Drug Administration, Department of Health and Human Services (Parts 1—1299) II Drug Enforcement Administration, Department of Justice (Parts 1300—1399) III Office of National Drug Control Policy (Parts 1400—1499) Title 22—Foreign Relations I Department of State (Parts 1—199) II Agency for International Development (Parts 200—299) III Peace Corps (Parts 300—399) IV International Joint Commission, United States and Canada (Parts 400—499) V Broadcasting Board of Governors (Parts 500—599) VII Overseas Private Investment Corporation (Parts 700—799) IX Foreign Service Grievance Board (Parts 900—999) X Inter-American Foundation (Parts 1000—1099) XI International Boundary and Water Commission, United States and Mexico, United States Section (Parts 1100—1199) XII United States International Development Cooperation Agency (Parts 1200—1299) XIII Millennium Challenge Corporation (Parts 1300—1399) XIV Foreign Service Labor Relations Board; Federal Labor Relations Authority; General Counsel of the Federal Labor Relations Authority; and the Foreign Service Impasse Disputes Panel (Parts 1400—1499) XV African Development Foundation (Parts 1500—1599) XVI Japan-United States Friendship Commission (Parts 1600—1699) XVII United States Institute of Peace (Parts 1700—1799) Title 23—Highways I Federal Highway Administration, Department of Transportation (Parts 1—999) II National Highway Traffic Safety Administration and Federal Highway Administration, Department of Transportation (Parts 1200—1299) III National Highway Traffic Safety Administration, Department of Transportation (Parts 1300—1399) Title 24—Housing and Urban Development Subtitle A—Office of the Secretary, Department of Housing and Urban Development (Parts 0—99) Subtitle B—Regulations Relating to Housing and Urban Development I Office of Assistant Secretary for Equal Opportunity, Department of Housing and Urban Development (Parts 100—199) II Office of Assistant Secretary for Housing-Federal Housing Commissioner, Department of Housing and Urban Development (Parts 200—299) III Government National Mortgage Association, Department of Housing and Urban Development (Parts 300—399) IV Office of Housing and Office of Multifamily Housing Assistance Restructuring, Department of Housing and Urban Development (Parts 400—499) V Office of Assistant Secretary for Community Planning and Development, Department of Housing and Urban Development (Parts 500—599) VI Office of Assistant Secretary for Community Planning and Development, Department of Housing and Urban Development (Parts 600—699) [Reserved] VII Office of the Secretary, Department of Housing and Urban Development (Housing Assistance Programs and Public and Indian Housing Programs) (Parts 700—799) VIII Office of the Assistant Secretary for Housing—Federal Housing Commissioner, Department of Housing and Urban Development (Section 8 Housing Assistance Programs, Section 202 Direct Loan Program, Section 202 Supportive Housing for the Elderly Program and Section 811 Supportive Housing for Persons With Disabilities Program) (Parts 800—899) IX Office of Assistant Secretary for Public and Indian Housing, Department of Housing and Urban Development (Parts 900—1699) XII Office of Inspector General, Department of Housing and Urban Development (Parts 2000—2099) XV Emergency Mortgage Insurance and Loan Programs, Department of Housing and Urban Development (Parts 2700—2799) [Reserved] XX Office of Assistant Secretary for Housing—Federal Housing Commissioner, Department of Housing and Urban Development (Parts 3200—3899) XXIV Board of Directors of the HOPE for Homeowners Program (Parts 4000—4099) [Reserved] XXV Neighborhood Reinvestment Corporation (Parts 4100—4199) Title 25—Indians I Bureau of Indian Affairs, Department of the Interior (Parts 1—299) II Indian Arts and Crafts Board, Department of the Interior (Parts 300—399) III National Indian Gaming Commission, Department of the Interior (Parts 500—599) IV Office of Navajo and Hopi Indian Relocation (Parts 700—899) V Bureau of Indian Affairs, Department of the Interior, and Indian Health Service, Department of Health and Human Services (Part 900—999) VI Office of the Assistant Secretary, Indian Affairs, Department of the Interior (Parts 1000—1199) VII Office of the Special Trustee for American Indians, Department of the Interior (Parts 1200—1299) Title 26—Internal Revenue I Internal Revenue Service, Department of the Treasury (Parts 1—End) Title 27—Alcohol, Tobacco Products and Firearms I Alcohol and Tobacco Tax and Trade Bureau, Department of the Treasury (Parts 1—399) II Bureau of Alcohol, Tobacco, Firearms, and Explosives, Department of Justice (Parts 400—699) Title 28—Judicial Administration I Department of Justice (Parts 0—299) III Federal Prison Industries, Inc., Department of Justice (Parts 300—399) V Bureau of Prisons, Department of Justice (Parts 500—599) VI Offices of Independent Counsel, Department of Justice (Parts 600—699) VII Office of Independent Counsel (Parts 700—799) VIII Court Services and Offender Supervision Agency for the District of Columbia (Parts 800—899) IX National Crime Prevention and Privacy Compact Council (Parts 900—999) XI Department of Justice and Department of State (Parts 1100—1199) Title 29—Labor Subtitle A—Office of the Secretary of Labor (Parts 0—99) Subtitle B—Regulations Relating to Labor I National Labor Relations Board (Parts 100—199) II Office of Labor-Management Standards, Department of Labor (Parts 200—299) III National Railroad Adjustment Board (Parts 300—399) IV Office of Labor-Management Standards, Department of Labor (Parts 400—499) V Wage and Hour Division, Department of Labor (Parts 500—899) IX Construction Industry Collective Bargaining Commission (Parts 900—999) X National Mediation Board (Parts 1200—1299) XII Federal Mediation and Conciliation Service (Parts 1400—1499) XIV Equal Employment Opportunity Commission (Parts 1600—1699) XVII Occupational Safety and Health Administration, Department of Labor (Parts 1900—1999) XX Occupational Safety and Health Review Commission (Parts 2200—2499) XXV Employee Benefits Security Administration, Department of Labor (Parts 2500—2599) XXVII Federal Mine Safety and Health Review Commission (Parts 2700—2799) XL Pension Benefit Guaranty Corporation (Parts 4000—4999) Title 30—Mineral Resources I Mine Safety and Health Administration, Department of Labor (Parts 1—199) II Bureau of Safety and Environmental Enforcement, Department of the Interior (Parts 200—299) IV Geological Survey, Department of the Interior (Parts 400—499) V Bureau of Ocean Energy Management, Department of the Interior (Parts 500—599) VII Office of Surface Mining Reclamation and Enforcement, Department of the Interior (Parts 700—999) XII Office of Natural Resources Revenue, Department of the Interior (Parts 1200—1299) Title 31—Money and Finance: Treasury Subtitle A—Office of the Secretary of the Treasury (Parts 0—50) Subtitle B—Regulations Relating to Money and Finance I Monetary Offices, Department of the Treasury (Parts 51—199) II Fiscal Service, Department of the Treasury (Parts 200—399) IV Secret Service, Department of the Treasury (Parts 400—499) V Office of Foreign Assets Control, Department of the Treasury (Parts 500—599) VI Bureau of Engraving and Printing, Department of the Treasury (Parts 600—699) VII Federal Law Enforcement Training Center, Department of the Treasury (Parts 700—799) VIII Office of Investment Security, Department of the Treasury (Parts 800—899) IX Federal Claims Collection Standards (Department of the Treasury—Department of Justice) (Parts 900—999) X Financial Crimes Enforcement Network, Department of the Treasury (Parts 1000—1099) Title 32—National Defense Subtitle A—Department of Defense I Office of the Secretary of Defense (Parts 1—399) V Department of the Army (Parts 400—699) VI Department of the Navy (Parts 700—799) VII Department of the Air Force (Parts 800—1099) Subtitle B—Other Regulations Relating to National Defense XII Department of Defense, Defense Logistics Agency (Parts 1200—1299) XVI Selective Service System (Parts 1600—1699) XVII Office of the Director of National Intelligence (Parts 1700—1799) XVIII National Counterintelligence Center (Parts 1800—1899) XIX Central Intelligence Agency (Parts 1900—1999) XX Information Security Oversight Office, National Archives and Records Administration (Parts 2000—2099) XXI National Security Council (Parts 2100—2199) XXIV Office of Science and Technology Policy (Parts 2400—2499) XXVII Office for Micronesian Status Negotiations (Parts 2700—2799) XXVIII Office of the Vice President of the United States (Parts 2800—2899) Title 33—Navigation and Navigable Waters I Coast Guard, Department of Homeland Security (Parts 1—199) II Corps of Engineers, Department of the Army, Department of Defense (Parts 200—399) IV Saint Lawrence Seaway Development Corporation, Department of Transportation (Parts 400—499) Title 34—Education Subtitle A—Office of the Secretary, Department of Education (Parts 1—99) Subtitle B—Regulations of the Offices of the Department of Education I Office for Civil Rights, Department of Education (Parts 100—199) II Office of Elementary and Secondary Education, Department of Education (Parts 200—299) III Office of Special Education and Rehabilitative Services, Department of Education (Parts 300—399) IV Office of Career, Technical and Adult Education, Department of Education (Parts 400—499) V Office of Bilingual Education and Minority Languages Affairs, Department of Education (Parts 500—599) [Reserved] VI Office of Postsecondary Education, Department of Education (Parts 600—699) VII Office of Educational Research and Improvement, Department of Education (Parts 700—799) [Reserved] Subtitle C—Regulations Relating to Education XI (Parts 1100—1199) [Reserved] XII National Council on Disability (Parts 1200—1299) Title 35 [Reserved] Title 36—Parks, Forests, and Public Property I National Park Service, Department of the Interior (Parts 1—199) II Forest Service, Department of Agriculture (Parts 200—299) III Corps of Engineers, Department of the Army (Parts 300—399) IV American Battle Monuments Commission (Parts 400—499) V Smithsonian Institution (Parts 500—599) VI [Reserved] VII Library of Congress (Parts 700—799) VIII Advisory Council on Historic Preservation (Parts 800—899) IX Pennsylvania Avenue Development Corporation (Parts 900—999) X Presidio Trust (Parts 1000—1099) XI Architectural and Transportation Barriers Compliance Board (Parts 1100—1199) XII National Archives and Records Administration (Parts 1200—1299) XV Oklahoma City National Memorial Trust (Parts 1500—1599) XVI Morris K. Udall Scholarship and Excellence in National Environmental Policy Foundation (Parts 1600—1699) Title 37—Patents, Trademarks, and Copyrights I United States Patent and Trademark Office, Department of Commerce (Parts 1—199) II U.S. Copyright Office, Library of Congress (Parts 200—299) III Copyright Royalty Board, Library of Congress (Parts 300—399) IV National Institute of Standards and Technology, Department of Commerce (Parts 400—599) Title 38—Pensions, Bonuses, and Veterans' Relief I Department of Veterans Affairs (Parts 0—199) II Armed Forces Retirement Home (Parts 200—299) Title 39—Postal Service I United States Postal Service (Parts 1—999) III Postal Regulatory Commission (Parts 3000—3099) Title 40—Protection of Environment I Environmental Protection Agency (Parts 1—1099) IV Environmental Protection Agency and Department of Justice (Parts 1400—1499) V Council on Environmental Quality (Parts 1500—1599) VI Chemical Safety and Hazard Investigation Board (Parts 1600—1699) VII Environmental Protection Agency and Department of Defense; Uniform National Discharge Standards for Vessels of the Armed Forces (Parts 1700—1799) VIII Gulf Coast Ecosystem Restoration Council (Parts 1800—1899) Title 41—Public Contracts and Property Management Subtitle A—Federal Procurement Regulations System [Note] Subtitle B—Other Provisions Relating to Public Contracts 50 Public Contracts, Department of Labor (Parts 50-1—50-999) 51 Committee for Purchase From People Who Are Blind or Severely Disabled (Parts 51-1—51-99) 60 Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor (Parts 60-1—60-999) 61 Office of the Assistant Secretary for Veterans' Employment and Training Service, Department of Labor (Parts 61-1—61-999) 62—100 [Reserved] Subtitle C—Federal Property Management Regulations System 101 Federal Property Management Regulations (Parts 101-1—101-99) 102 Federal Management Regulation (Parts 102-1—102-299) 103—104 [Reserved] 105 General Services Administration (Parts 105-1—105-999) 109 Department of Energy Property Management Regulations (Parts 109-1—109-99) 114 Department of the Interior (Parts 114-1—114-99) 115 Environmental Protection Agency (Parts 115-1—115-99) 128 Department of Justice (Parts 128-1—128-99) 129—200 [Reserved] Subtitle D—Other Provisions Relating to Property Management [Reserved] Subtitle E—Federal Information Resources Management Regulations System [Reserved] Subtitle F—Federal Travel Regulation System 300 General (Parts 300-1—300-99) 301 Temporary Duty (TDY) Travel Allowances (Parts 301-1—301-99) 302 Relocation Allowances (Parts 302-1—302-99) 303 Payment of Expenses Connected with the Death of Certain Employees (Part 303-1—303-99) 304 Payment of Travel Expenses from a Non-Federal Source (Parts 304-1—304-99) Title 42—Public Health I Public Health Service, Department of Health and Human Services (Parts 1—199) IV Centers for Medicare & Medicaid Services, Department of Health and Human Services (Parts 400—699) V Office of Inspector General-Health Care, Department of Health and Human Services (Parts 1000—1099) Title 43—Public Lands: Interior Subtitle A—Office of the Secretary of the Interior (Parts 1—199) Subtitle B—Regulations Relating to Public Lands I Bureau of Reclamation, Department of the Interior (Parts 400—999) II Bureau of Land Management, Department of the Interior (Parts 1000—9999) III Utah Reclamation Mitigation and Conservation Commission (Parts 10000—10099) Title 44—Emergency Management and Assistance I Federal Emergency Management Agency, Department of Homeland Security (Parts 0—399) IV Department of Commerce and Department of Transportation (Parts 400—499) Title 45—Public Welfare Subtitle A—Department of Health and Human Services (Parts 1—199) Subtitle B—Regulations Relating to Public Welfare II Office of Family Assistance (Assistance Programs), Administration for Children and Families, Department of Health and Human Services (Parts 200—299) III Office of Child Support Enforcement (Child Support Enforcement Program), Administration for Children and Families, Department of Health and Human Services (Parts 300—399) IV Office of Refugee Resettlement, Administration for Children and Families, Department of Health and Human Services (Parts 400—499) V Foreign Claims Settlement Commission of the United States, Department of Justice (Parts 500—599) VI National Science Foundation (Parts 600—699) VII Commission on Civil Rights (Parts 700—799) VIII Office of Personnel Management (Parts 800—899) IX Denali Commission (Parts 900—999) X Office of Community Services, Administration for Children and Families, Department of Health and Human Services (Parts 1000—1099) XI National Foundation on the Arts and the Humanities (Parts 1100—1199) XII Corporation for National and Community Service (Parts 1200—1299) XIII Administration for Children and Families, Department of Health and Human Services (Parts 1300—1399) XVI Legal Services Corporation (Parts 1600—1699) XVII National Commission on Libraries and Information Science (Parts 1700—1799) XVIII Harry S. Truman Scholarship Foundation (Parts 1800—1899) XXI Commission of Fine Arts (Parts 2100—2199) XXIII Arctic Research Commission (Parts 2300—2399) XXIV James Madison Memorial Fellowship Foundation (Parts 2400—2499) XXV Corporation for National and Community Service (Parts 2500—2599) Title 46—Shipping I Coast Guard, Department of Homeland Security (Parts 1—199) II Maritime Administration, Department of Transportation (Parts 200—399) III Coast Guard (Great Lakes Pilotage), Department of Homeland Security (Parts 400—499) IV Federal Maritime Commission (Parts 500—599) Title 47—Telecommunication I Federal Communications Commission (Parts 0—199) II Office of Science and Technology Policy and National Security Council (Parts 200—299) III National Telecommunications and Information Administration, Department of Commerce (Parts 300—399) IV National Telecommunications and Information Administration, Department of Commerce, and National Highway Traffic Safety Administration, Department of Transportation (Parts 400—499) V The First Responder Network Authority (Parts 500—599) Title 48—Federal Acquisition Regulations System 1 Federal Acquisition Regulation (Parts 1—99) 2 Defense Acquisition Regulations System, Department of Defense (Parts 200—299) 3 Department of Health and Human Services (Parts 300—399) 4 Department of Agriculture (Parts 400—499) 5 General Services Administration (Parts 500—599) 6 Department of State (Parts 600—699) 7 Agency for International Development (Parts 700—799) 8 Department of Veterans Affairs (Parts 800—899) 9 Department of Energy (Parts 900—999) 10 Department of the Treasury (Parts 1000—1099) 12 Department of Transportation (Parts 1200—1299) 13 Department of Commerce (Parts 1300—1399) 14 Department of the Interior (Parts 1400—1499) 15 Environmental Protection Agency (Parts 1500—1599) 16 Office of Personnel Management, Federal Employees Health Benefits Acquisition Regulation (Parts 1600—1699) 17 Office of Personnel Management (Parts 1700—1799) 18 National Aeronautics and Space Administration (Parts 1800—1899) 19 Broadcasting Board of Governors (Parts 1900—1999) 20 Nuclear Regulatory Commission (Parts 2000—2099) 21 Office of Personnel Management, Federal Employees Group Life Insurance Federal Acquisition Regulation (Parts 2100—2199) 23 Social Security Administration (Parts 2300—2399) 24 Department of Housing and Urban Development (Parts 2400—2499) 25 National Science Foundation (Parts 2500—2599) 28 Department of Justice (Parts 2800—2899) 29 Department of Labor (Parts 2900—2999) 30 Department of Homeland Security, Homeland Security Acquisition Regulation (HSAR) (Parts 3000—3099) 34 Department of Education Acquisition Regulation (Parts 3400—3499) 51 Department of the Army Acquisition Regulations (Parts 5100—5199) [Reserved] 52 Department of the Navy Acquisition Regulations (Parts 5200—5299) 53 Department of the Air Force Federal Acquisition Regulation Supplement (Parts 5300—5399) [Reserved] 54 Defense Logistics Agency, Department of Defense (Parts 5400—5499) 57 African Development Foundation (Parts 5700—5799) 61 Civilian Board of Contract Appeals, General Services Administration (Parts 6100—6199) 99 Cost Accounting Standards Board, Office of Federal Procurement Policy, Office of Management and Budget (Parts 9900—9999) Title 49—Transportation Subtitle A—Office of the Secretary of Transportation (Parts 1—99) Subtitle B—Other Regulations Relating to Transportation I Pipeline and Hazardous Materials Safety Administration, Department of Transportation (Parts 100—199) II Federal Railroad Administration, Department of Transportation (Parts 200—299) III Federal Motor Carrier Safety Administration, Department of Transportation (Parts 300—399) IV Coast Guard, Department of Homeland Security (Parts 400—499) V National Highway Traffic Safety Administration, Department of Transportation (Parts 500—599) VI Federal Transit Administration, Department of Transportation (Parts 600—699) VII National Railroad Passenger Corporation (AMTRAK) (Parts 700—799) VIII National Transportation Safety Board (Parts 800—999) X Surface Transportation Board (Parts 1000—1399) XI Research and Innovative Technology Administration, Department of Transportation (Parts 1400—1499) [Reserved] XII Transportation Security Administration, Department of Homeland Security (Parts 1500—1699) Title 50—Wildlife and Fisheries I United States Fish and Wildlife Service, Department of the Interior (Parts 1—199) II National Marine Fisheries Service, National Oceanic and Atmospheric Administration, Department of Commerce (Parts 200—299) III International Fishing and Related Activities (Parts 300—399) IV Joint Regulations (United States Fish and Wildlife Service, Department of the Interior and National Marine Fisheries Service, National Oceanic and Atmospheric Administration, Department of Commerce); Endangered Species Committee Regulations (Parts 400—499) V Marine Mammal Commission (Parts 500—599) VI Fishery Conservation and Management, National Oceanic and Atmospheric Administration, Department of Commerce (Parts 600—699) Alphabetical List of Agencies Appearing in the CFR (Revised as of April 1, 2020) Agency CFR Title, Subtitle or Chapter Administrative Conference of the United States 1, III Advisory Council on Historic Preservation 36, VIII Advocacy and Outreach, Office of 7, XXV Afghanistan Reconstruction, Special Inspector General for 5, LXXXIII African Development Foundation 22, XV Federal Acquisition Regulation 48, 57 Agency for International Development 2, VII; 22, II Federal Acquisition Regulation 48, 7 Agricultural Marketing Service 7, I, VIII, IX, X, XI; 9, II Agricultural Research Service 7, V Agriculture, Department of 2, IV; 5, LXXIII Advocacy and Outreach, Office of 7, XXV Agricultural Marketing Service 7, I, VIII, IX, X, XI; 9, II Agricultural Research Service 7, V Animal and Plant Health Inspection Service 7, III; 9, I Chief Financial Officer, Office of 7, XXX Commodity Credit Corporation 7, XIV Economic Research Service 7, XXXVII Energy Policy and New Uses, Office of 2, IX; 7, XXIX Environmental Quality, Office of 7, XXXI Farm Service Agency 7, VII, XVIII Federal Acquisition Regulation 48, 4 Federal Crop Insurance Corporation 7, IV Food and Nutrition Service 7, II Food Safety and Inspection Service 9, III Foreign Agricultural Service 7, XV Forest Service 36, II Information Resources Management, Office of 7, XXVII Inspector General, Office of 7, XXVI National Agricultural Library 7, XLI National Agricultural Statistics Service 7, XXXVI National Institute of Food and Agriculture 7, XXXIV Natural Resources Conservation Service 7, VI Operations, Office of 7, XXVIII Procurement and Property Management, Office of 7, XXXII Rural Business-Cooperative Service 7, XVIII, XLII Rural Development Administration 7, XLII Rural Housing Service 7, XVIII, XXXV Rural Utilities Service 7, XVII, XVIII, XLII Secretary of Agriculture, Office of 7, Subtitle A Transportation, Office of 7, XXXIII World Agricultural Outlook Board 7, XXXVIII Air Force, Department of 32, VII Federal Acquisition Regulation Supplement 48, 53 Air Transportation Stabilization Board 14, VI Alcohol and Tobacco Tax and Trade Bureau 27, I Alcohol, Tobacco, Firearms, and Explosives, Bureau of 27, II AMTRAK 49, VII American Battle Monuments Commission 36, IV American Indians, Office of the Special Trustee 25, VII Animal and Plant Health Inspection Service 7, III; 9, I Appalachian Regional Commission 5, IX Architectural and Transportation Barriers Compliance Board 36, XI Arctic Research Commission 45, XXIII Armed Forces Retirement Home 5, XI; 38, II Army, Department of 32, V Engineers, Corps of 33, II; 36, III Federal Acquisition Regulation 48, 51 Bilingual Education and Minority Languages Affairs, Office of 34, V Blind or Severely Disabled, Committee for Purchase from People Who Are 41, 51 Broadcasting Board of Governors 22, V Federal Acquisition Regulation 48, 19 Career, Technical, and Adult Education, Office of 34, IV Census Bureau 15, I Centers for Medicare & Medicaid Services 42, IV Central Intelligence Agency 32, XIX Chemical Safety and Hazard Investigation Board 40, VI Chief Financial Officer, Office of 7, XXX Child Support Enforcement, Office of 45, III Children and Families, Administration for 45, II, III, IV, X, XIII Civil Rights, Commission on 5, LXVIII; 45, VII Civil Rights, Office for 34, I Council of the Inspectors General on Integrity and Efficiency 5, XCVIII Court Services and Offender Supervision Agency for the District of Columbia 5, LXX Coast Guard 33, I; 46, I; 49, IV Coast Guard (Great Lakes Pilotage) 46, III Commerce, Department of 2, XIII; 44, IV; 50, VI Census Bureau 15, I Economic Analysis, Bureau of 15, VIII Economic Development Administration 13, III Emergency Management and Assistance 44, IV Federal Acquisition Regulation 48, 13 Foreign-Trade Zones Board 15, IV Industry and Security, Bureau of 15, VII International Trade Administration 15, III; 19, III National Institute of Standards and Technology 15, II; 37, IV National Marine Fisheries Service 50, II, IV National Oceanic and Atmospheric Administration 15, IX; 50, II, III, IV, VI National Technical Information Service 15, XI National Telecommunications and Information Administration 15, XXIII; 47, III, IV National Weather Service 15, IX Patent and Trademark Office, United States 37, I Secretary of Commerce, Office of 15, Subtitle A Commercial Space Transportation 14, III Commodity Credit Corporation 7, XIV Commodity Futures Trading Commission 5, XLI; 17, I Community Planning and Development, Office of Assistant Secretary for 24, V, VI Community Services, Office of 45, X Comptroller of the Currency 12, I Construction Industry Collective Bargaining Commission 29, IX Consumer Financial Protection Bureau 5, LXXXIV; 12, X Consumer Product Safety Commission 5, LXXI; 16, II Copyright Royalty Board 37, III Corporation for National and Community Service 2, XXII; 45, XII, XXV Cost Accounting Standards Board 48, 99 Council on Environmental Quality 40, V Court Services and Offender Supervision Agency for the District of Columbia 5, LXX; 28, VIII Customs and Border Protection 19, I Defense Contract Audit Agency 32, I Defense, Department of 2, XI; 5, XXVI; 32, Subtitle A; 40, VII Advanced Research Projects Agency 32, I Air Force Department 32, VII Army Department 32, V; 33, II; 36, III; 48, 51 Defense Acquisition Regulations System 48, 2 Defense Intelligence Agency 32, I Defense Logistics Agency 32, I, XII; 48, 54 Engineers, Corps of 33, II; 36, III National Imagery and Mapping Agency 32, I Navy, Department of 32, VI; 48, 52 Secretary of Defense, Office of 2, XI; 32, I Defense Contract Audit Agency 32, I Defense Intelligence Agency 32, I Defense Logistics Agency 32, XII; 48, 54 Defense Nuclear Facilities Safety Board 10, XVII Delaware River Basin Commission 18, III Denali Commission 45, IX Disability, National Council on 5, C; 34, XII District of Columbia, Court Services and Offender Supervision Agency for the 5, LXX; 28, VIII Drug Enforcement Administration 21, II East-West Foreign Trade Board 15, XIII Economic Analysis, Bureau of 15, VIII Economic Development Administration 13, III Economic Research Service 7, XXXVII Education, Department of 2, XXXIV; 5, LIII Bilingual Education and Minority Languages Affairs, Office of 34, V Career, Technical, and Adult Education, Office of 34, IV Civil Rights, Office for 34, I Educational Research and Improvement, Office of 34, VII Elementary and Secondary Education, Office of 34, II Federal Acquisition Regulation 48, 34 Postsecondary Education, Office of 34, VI Secretary of Education, Office of 34, Subtitle A Special Education and Rehabilitative Services, Office of 34, III Educational Research and Improvement, Office of 34, VII Election Assistance Commission 2, LVIII; 11, II Elementary and Secondary Education, Office of 34, II Emergency Oil and Gas Guaranteed Loan Board 13, V Emergency Steel Guarantee Loan Board 13, IV Employee Benefits Security Administration 29, XXV Employees' Compensation Appeals Board 20, IV Employees Loyalty Board 5, V Employment and Training Administration 20, V Employment Policy, National Commission for 1, IV Employment Standards Administration 20, VI Endangered Species Committee 50, IV Energy, Department of 2, IX; 5, XXIII; 10, II, III, X Federal Acquisition Regulation 48, 9 Federal Energy Regulatory Commission 5, XXIV; 18, I Property Management Regulations 41, 109 Energy, Office of 7, XXIX Engineers, Corps of 33, II; 36, III Engraving and Printing, Bureau of 31, VI Environmental Protection Agency 2, XV; 5, LIV; 40, I, IV, VII Federal Acquisition Regulation 48, 15 Property Management Regulations 41, 115 Environmental Quality, Office of 7, XXXI Equal Employment Opportunity Commission 5, LXII; 29, XIV Equal Opportunity, Office of Assistant Secretary for 24, I Executive Office of the President 3, I Environmental Quality, Council on 40, V Management and Budget, Office of 2, Subtitle A; 5, III, LXXVII; 14, VI; 48, 99 National Drug Control Policy, Office of 2, XXXVI; 21, III National Security Council 32, XXI; 47, II Presidential Documents 3 Science and Technology Policy, Office of 32, XXIV; 47, II Trade Representative, Office of the United States 15, XX Export-Import Bank of the United States 2, XXXV; 5, LII; 12, IV Family Assistance, Office of 45, II Farm Credit Administration 5, XXXI; 12, VI Farm Credit System Insurance Corporation 5, XXX; 12, XIV Farm Service Agency 7, VII, XVIII Federal Acquisition Regulation 48, 1 Federal Aviation Administration 14, I Commercial Space Transportation 14, III Federal Claims Collection Standards 31, IX Federal Communications Commission 5, XXIX; 47, I Federal Contract Compliance Programs, Office of 41, 60 Federal Crop Insurance Corporation 7, IV Federal Deposit Insurance Corporation 5, XXII; 12, III Federal Election Commission 5, XXXVII; 11, I Federal Emergency Management Agency 44, I Federal Employees Group Life Insurance Federal Acquisition Regulation 48, 21 Federal Employees Health Benefits Acquisition Regulation 48, 16 Federal Energy Regulatory Commission 5, XXIV; 18, I Federal Financial Institutions Examination Council 12, XI Federal Financing Bank 12, VIII Federal Highway Administration 23, I, II Federal Home Loan Mortgage Corporation 1, IV Federal Housing Enterprise Oversight Office 12, XVII Federal Housing Finance Agency 5, LXXX; 12, XII Federal Housing Finance Board 12, IX Federal Labor Relations Authority 5, XIV, XLIX; 22, XIV Federal Law Enforcement Training Center 31, VII Federal Management Regulation 41, 102 Federal Maritime Commission 46, IV Federal Mediation and Conciliation Service 29, XII Federal Mine Safety and Health Review Commission 5, LXXIV; 29, XXVII Federal Motor Carrier Safety Administration 49, III Federal Prison Industries, Inc. 28, III Federal Procurement Policy Office 48, 99 Federal Property Management Regulations 41, 101 Federal Railroad Administration 49, II Federal Register, Administrative Committee of 1, I Federal Register, Office of 1, II Federal Reserve System 12, II Board of Governors 5, LVIII Federal Retirement Thrift Investment Board 5, VI, LXXVI Federal Service Impasses Panel 5, XIV Federal Trade Commission 5, XLVII; 16, I Federal Transit Administration 49, VI Federal Travel Regulation System 41, Subtitle F Financial Crimes Enforcement Network 31, X Financial Research Office 12, XVI Financial Stability Oversight Council 12, XIII Fine Arts, Commission of 45, XXI Fiscal Service 31, II Fish and Wildlife Service, United States 50, I, IV Food and Drug Administration 21, I Food and Nutrition Service 7, II Food Safety and Inspection Service 9, III Foreign Agricultural Service 7, XV Foreign Assets Control, Office of 31, V Foreign Claims Settlement Commission of the United States 45, V Foreign Service Grievance Board 22, IX Foreign Service Impasse Disputes Panel 22, XIV Foreign Service Labor Relations Board 22, XIV Foreign-Trade Zones Board 15, IV Forest Service 36, II General Services Administration 5, LVII; 41, 105 Contract Appeals, Board of 48, 61 Federal Acquisition Regulation 48, 5 Federal Management Regulation 41, 102 Federal Property Management Regulations 41, 101 Federal Travel Regulation System 41, Subtitle F General 41, 300 Payment From a Non-Federal Source for Travel Expenses 41, 304 Payment of Expenses Connected With the Death of Certain Employees 41, 303 Relocation Allowances 41, 302 Temporary Duty (TDY) Travel Allowances 41, 301 Geological Survey 30, IV Government Accountability Office 4, I Government Ethics, Office of 5, XVI Government National Mortgage Association 24, III Grain Inspection, Packers and Stockyards Administration 7, VIII; 9, II Gulf Coast Ecosystem Restoration Council 2, LIX; 40, VIII Harry S. Truman Scholarship Foundation 45, XVIII Health and Human Services, Department of 2, III; 5, XLV; 45, Subtitle A Centers for Medicare & Medicaid Services 42, IV Child Support Enforcement, Office of 45, III Children and Families, Administration for 45, II, III, IV, X, XIII Community Services, Office of 45, X Family Assistance, Office of 45, II Federal Acquisition Regulation 48, 3 Food and Drug Administration 21, I Indian Health Service 25, V Inspector General (Health Care), Office of 42, V Public Health Service 42, I Refugee Resettlement, Office of 45, IV Homeland Security, Department of 2, XXX; 5, XXXVI; 6, I; 8, I Coast Guard 33, I; 46, I; 49, IV Coast Guard (Great Lakes Pilotage) 46, III Customs and Border Protection 19, I Federal Emergency Management Agency 44, I Human Resources Management and Labor Relations Systems 5, XCVII Immigration and Customs Enforcement Bureau 19, IV Transportation Security Administration 49, XII HOPE for Homeowners Program, Board of Directors of 24, XXIV Housing and Urban Development, Department of 2, XXIV; 5, LXV; 24, Subtitle B Community Planning and Development, Office of Assistant Secretary for 24, V, VI Equal Opportunity, Office of Assistant Secretary for 24, I Federal Acquisition Regulation 48, 24 Federal Housing Enterprise Oversight, Office of 12, XVII Government National Mortgage Association 24, III Housing—Federal Housing Commissioner, Office of Assistant Secretary for 24, II, VIII, X, XX Housing, Office of, and Multifamily Housing Assistance Restructuring, Office of 24, IV Inspector General, Office of 24, XII Public and Indian Housing, Office of Assistant Secretary for 24, IX Secretary, Office of 24, Subtitle A, VII Housing—Federal Housing Commissioner, Office of Assistant Secretary for 24, II, VIII, X, XX Housing, Office of, and Multifamily Housing Assistance Restructuring, Office of 24, IV Immigration and Customs Enforcement Bureau 19, IV Immigration Review, Executive Office for 8, V Independent Counsel, Office of 28, VII Independent Counsel, Offices of 28, VI Indian Affairs, Bureau of 25, I, V Indian Affairs, Office of the Assistant Secretary 25, VI Indian Arts and Crafts Board 25, II Indian Health Service 25, V Industry and Security, Bureau of 15, VII Information Resources Management, Office of 7, XXVII Information Security Oversight Office, National Archives and Records Administration 32, XX Inspector General Agriculture Department 7, XXVI Health and Human Services Department 42, V Housing and Urban Development Department 24, XII, XV Institute of Peace, United States 22, XVII Inter-American Foundation 5, LXIII; 22, X Interior, Department of 2, XIV American Indians, Office of the Special Trustee 25, VII Endangered Species Committee 50, IV Federal Acquisition Regulation 48, 14 Federal Property Management Regulations System 41, 114 Fish and Wildlife Service, United States 50, I, IV Geological Survey 30, IV Indian Affairs, Bureau of 25, I, V Indian Affairs, Office of the Assistant Secretary 25, VI Indian Arts and Crafts Board 25, II Land Management, Bureau of 43, II National Indian Gaming Commission 25, III National Park Service 36, I Natural Resource Revenue, Office of 30, XII Ocean Energy Management, Bureau of 30, V Reclamation, Bureau of 43, I Safety and Enforcement Bureau, Bureau of 30, II Secretary of the Interior, Office of 2, XIV; 43, Subtitle A Surface Mining Reclamation and Enforcement, Office of 30, VII Internal Revenue Service 26, I International Boundary and Water Commission, United States and Mexico, United States Section 22, XI International Development, United States Agency for 22, II Federal Acquisition Regulation 48, 7 International Development Cooperation Agency, United States 22, XII International Development Finance Corporation, U.S. 5, XXXIII; 22, VII International Joint Commission, United States and Canada 22, IV International Organizations Employees Loyalty Board 5, V International Trade Administration 15, III; 19, III International Trade Commission, United States 19, II Interstate Commerce Commission 5, XL Investment Security, Office of 31, VIII James Madison Memorial Fellowship Foundation 45, XXIV Japan-United States Friendship Commission 22, XVI Joint Board for the Enrollment of Actuaries 20, VIII Justice, Department of 2, XXVIII; 5, XXVIII; 28, I, XI; 40, IV Alcohol, Tobacco, Firearms, and Explosives, Bureau of 27, II Drug Enforcement Administration 21, II Federal Acquisition Regulation 48, 28 Federal Claims Collection Standards 31, IX Federal Prison Industries, Inc. 28, III Foreign Claims Settlement Commission of the United States 45, V Immigration Review, Executive Office for 8, V Independent Counsel, Offices of 28, VI Prisons, Bureau of 28, V Property Management Regulations 41, 128 Labor, Department of 2, XXIX; 5, XLII Employee Benefits Security Administration 29, XXV Employees' Compensation Appeals Board 20, IV Employment and Training Administration 20, V Employment Standards Administration 20, VI Federal Acquisition Regulation 48, 29 Federal Contract Compliance Programs, Office of 41, 60 Federal Procurement Regulations System 41, 50 Labor-Management Standards, Office of 29, II, IV Mine Safety and Health Administration 30, I Occupational Safety and Health Administration 29, XVII Public Contracts 41, 50 Secretary of Labor, Office of 29, Subtitle A Veterans' Employment and Training Service, Office of the Assistant Secretary for 41, 61; 20, IX Wage and Hour Division 29, V Workers' Compensation Programs, Office of 20, I, VII Labor-Management Standards, Office of 29, II, IV Land Management, Bureau of 43, II Legal Services Corporation 45, XVI Libraries and Information Science, National Commission on 45, XVII Library of Congress 36, VII Copyright Royalty Board 37, III U.S. Copyright Office 37, II Management and Budget, Office of 5, III, LXXVII; 14, VI; 48, 99 Marine Mammal Commission 50, V Maritime Administration 46, II Merit Systems Protection Board 5, II, LXIV Micronesian Status Negotiations, Office for 32, XXVII Military Compensation and Retirement Modernization Commission 5, XCIX Millennium Challenge Corporation 22, XIII Mine Safety and Health Administration 30, I Minority Business Development Agency 15, XIV Miscellaneous Agencies 1, IV Monetary Offices 31, I Morris K. Udall Scholarship and Excellence in National Environmental Policy Foundation 36, XVI Museum and Library Services, Institute of 2, XXXI National Aeronautics and Space Administration 2, XVIII; 5, LIX; 14, V Federal Acquisition Regulation 48, 18 National Agricultural Library 7, XLI National Agricultural Statistics Service 7, XXXVI National and Community Service, Corporation for 2, XXII; 45, XII, XXV National Archives and Records Administration 2, XXVI; 5, LXVI; 36, XII Information Security Oversight Office 32, XX National Capital Planning Commission 1, IV, VI National Counterintelligence Center 32, XVIII National Credit Union Administration 5, LXXXVI; 12, VII National Crime Prevention and Privacy Compact Council 28, IX National Drug Control Policy, Office of 2, XXXVI; 21, III National Endowment for the Arts 2, XXXII National Endowment for the Humanities 2, XXXIII National Foundation on the Arts and the Humanities 45, XI National Geospatial-Intelligence Agency 32, I National Highway Traffic Safety Administration 23, II, III; 47, VI; 49, V National Imagery and Mapping Agency 32, I National Indian Gaming Commission 25, III National Institute of Food and Agriculture 7, XXXIV National Institute of Standards and Technology 15, II; 37, IV National Intelligence, Office of Director of 5, IV; 32, XVII National Labor Relations Board 5, LXI; 29, I National Marine Fisheries Service 50, II, IV National Mediation Board 5, CI; 29, X National Oceanic and Atmospheric Administration 15, IX; 50, II, III, IV, VI National Park Service 36, I National Railroad Adjustment Board 29, III National Railroad Passenger Corporation (AMTRAK) 49, VII National Science Foundation 2, XXV; 5, XLIII; 45, VI Federal Acquisition Regulation 48, 25 National Security Council 32, XXI National Security Council and Office of Science and Technology Policy 47, II National Technical Information Service 15, XI National Telecommunications and Information Administration 15, XXIII; 47, III, IV, V National Transportation Safety Board 49, VIII Natural Resources Conservation Service 7, VI Natural Resource Revenue, Office of 30, XII Navajo and Hopi Indian Relocation, Office of 25, IV Navy, Department of 32, VI Federal Acquisition Regulation 48, 52 Neighborhood Reinvestment Corporation 24, XXV Northeast Interstate Low-Level Radioactive Waste Commission 10, XVIII Nuclear Regulatory Commission 2, XX; 5, XLVIII; 10, I Federal Acquisition Regulation 48, 20 Occupational Safety and Health Administration 29, XVII Occupational Safety and Health Review Commission 29, XX Ocean Energy Management, Bureau of 30, V Oklahoma City National Memorial Trust 36, XV Operations Office 7, XXVIII Patent and Trademark Office, United States 37, I Payment From a Non-Federal Source for Travel Expenses 41, 304 Payment of Expenses Connected With the Death of Certain Employees 41, 303 Peace Corps 2, XXXVII; 22, III Pennsylvania Avenue Development Corporation 36, IX Pension Benefit Guaranty Corporation 29, XL Personnel Management, Office of 5, I, IV, XXXV; 45, VIII Human Resources Management and Labor Relations Systems, Department of Homeland Security 5, XCVII Federal Acquisition Regulation 48, 17 Federal Employees Group Life Insurance Federal Acquisition Regulation 48, 21 Federal Employees Health Benefits Acquisition Regulation 48, 16 Pipeline and Hazardous Materials Safety Administration 49, I Postal Regulatory Commission 5, XLVI; 39, III Postal Service, United States 5, LX; 39, I Postsecondary Education, Office of 34, VI President's Commission on White House Fellowships 1, IV Presidential Documents 3 Presidio Trust 36, X Prisons, Bureau of 28, V Privacy and Civil Liberties Oversight Board 6, X Procurement and Property Management, Office of 7, XXXII Public Contracts, Department of Labor 41, 50 Public and Indian Housing, Office of Assistant Secretary for 24, IX Public Health Service 42, I Railroad Retirement Board 20, II Reclamation, Bureau of 43, I Refugee Resettlement, Office of 45, IV Relocation Allowances 41, 302 Research and Innovative Technology Administration 49, XI Rural Business-Cooperative Service 7, XVIII, XLII Rural Development Administration 7, XLII Rural Housing Service 7, XVIII, XXXV Rural Utilities Service 7, XVII, XVIII, XLII Safety and Environmental Enforcement, Bureau of 30, II Saint Lawrence Seaway Development Corporation 33, IV Science and Technology Policy, Office of 32, XXIV Science and Technology Policy, Office of, and National Security Council 47, II Secret Service 31, IV Securities and Exchange Commission 5, XXXIV; 17, II Selective Service System 32, XVI Small Business Administration 2, XXVII; 13, I Smithsonian Institution 36, V Social Security Administration 2, XXIII; 20, III; 48, 23 Soldiers' and Airmen's Home, United States 5, XI Special Counsel, Office of 5, VIII Special Education and Rehabilitative Services, Office of 34, III State, Department of 2, VI; 22, I; 28, XI Federal Acquisition Regulation 48, 6 Surface Mining Reclamation and Enforcement, Office of 30, VII Surface Transportation Board 49, X Susquehanna River Basin Commission 18, VIII Tennessee Valley Authority 5, LXIX; 18, XIII Trade Representative, United States, Office of 15, XX Transportation, Department of 2, XII; 5, L Commercial Space Transportation 14, III Emergency Management and Assistance 44, IV Federal Acquisition Regulation 48, 12 Federal Aviation Administration 14, I Federal Highway Administration 23, I, II Federal Motor Carrier Safety Administration 49, III Federal Railroad Administration 49, II Federal Transit Administration 49, VI Maritime Administration 46, II National Highway Traffic Safety Administration 23, II, III; 47, IV; 49, V Pipeline and Hazardous Materials Safety Administration 49, I Saint Lawrence Seaway Development Corporation 33, IV Secretary of Transportation, Office of 14, II; 49, Subtitle A Transportation Statistics Bureau 49, XI Transportation, Office of 7, XXXIII Transportation Security Administration 49, XII Transportation Statistics Bureau 49, XI Travel Allowances, Temporary Duty (TDY) 41, 301 Treasury, Department of the 2, X; 5, XXI; 12, XV; 17, IV; 31, IX Alcohol and Tobacco Tax and Trade Bureau 27, I Community Development Financial Institutions Fund 12, XVIII Comptroller of the Currency 12, I Customs and Border Protection 19, I Engraving and Printing, Bureau of 31, VI Federal Acquisition Regulation 48, 10 Federal Claims Collection Standards 31, IX Federal Law Enforcement Training Center 31, VII Financial Crimes Enforcement Network 31, X Fiscal Service 31, II Foreign Assets Control, Office of 31, V Internal Revenue Service 26, I Investment Security, Office of 31, VIII Monetary Offices 31, I Secret Service 31, IV Secretary of the Treasury, Office of 31, Subtitle A Truman, Harry S. Scholarship Foundation 45, XVIII United States and Canada, International Joint Commission 22, IV United States and Mexico, International Boundary and Water Commission, United States Section 22, XI U.S. Copyright Office 37, II Utah Reclamation Mitigation and Conservation Commission 43, III Veterans Affairs, Department of 2, VIII; 38, I Federal Acquisition Regulation 48, 8 Veterans' Employment and Training Service, Office of the Assistant Secretary for 41, 61; 20, IX Vice President of the United States, Office of 32, XXVIII Wage and Hour Division 29, V Water Resources Council 18, VI Workers' Compensation Programs, Office of 20, I, VII World Agricultural Outlook Board 7, XXXVIII 26 CFR (4-1-20 Edition) OMB Control Numbers Table of OMB Control Numbers

The OMB control numbers for chapter I of title 26 were consolidated into §§ 601.9000 and 602.101 at 50 FR 10221, Mar. 14, 1985. At 61 FR 58008, Nov. 12, 1996, § 601.9000 was removed. Section 602.101 is reprinted below for the convenience of the user.

Pt. 602 PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
§ 602.101 OMB Control numbers.

(a) Purpose. This part collects and displays the control numbers assigned to collections of information in Internal Revenue Service regulations by the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1980. The Internal Revenue Service intends that this part comply with the requirements of §§ 1320.7(f), 1320.12, 1320.13, and 1320.14 of 5 CFR part 1320 (OMB regulations implementing the Paperwork Reduction Act), for the display of control numbers assigned by OMB to collections of information in Internal Revenue Service regulations. This part does not display control numbers assigned by the Office of Management and Budget to collections of information of the Bureau of Alcohol, Tobacco, and Firearms.

(b) Display.

CFR part or section where identified and described Current OMB control No. 1.1(h)-1(e) 1545-1654 1.25-1T 1545-0922 1545-0930 1.25-2T 1545-0922 1545-0930 1.25-3T 1545-0922 1545-0930 1.25-4T 1545-0922 1.25-5T 1545-0922 1.25-6T 1545-0922 1.25-7T 1545-0922 1.25-8T 1545-0922 1.25A-1 1545-1630 1.28-1 1545-0619 1.31-2 1545-0074 1.32-2 1545-0074 1.32-3 1545-1575 1.36B-5 1545-2232 1.37-1 1545-0074 1.37-3 1545-0074 1.41-2 1545-0619 1.41-3 1545-0619 1.41-4A 1545-0074 1.41-4 (b) and (c) 1545-0074 1.41-8(b) 1545-1625 1.41-8(d) 1545-0732 1.41-9 1545-0619 1.42-1T 1545-0984 1545-0988 1.42-5 1545-1357 1.42-6 1545-1102 1.42-8 1545-1102 1.42-10 1545-1102 1.42-13 1545-1357 1.42-14 1545-1423 1.42-17 1545-1357 1.42-18 1545-2088 1.43-3(a)(3) 1545-1292 1.43-3(b)(3) 1545-1292 1.44B-1 1545-0219 1.45D-1 1545-1765 1.45G-1 1545-2031 1.46-1 1545-0123 1545-0155 1.46-3 1545-0155 1.46-4 1545-0155 1.46-5 1545-0155 1.46-6 1545-0155 1.46-8 1545-0155 1.46-9 1545-0155 1.46-10 1545-0118 1.47-1 1545-0155 1545-0166 1.47-3 1545-0155 1545-0166 1.47-4 1545-0123 1.47-5 1545-0092 1.47-6 1545-0099 1.48-3 1545-0155 1.48-4 1545-0155 1545-0808 1.48-5 1545-0155 1.48-6 1545-0155 1.48-12 1545-0155 1545-1783 1.50A-1 1545-0895 1.50A-2 1545-0895 1.50A-3 1545-0895 1.50A-4 1545-0895 1.50A-5 1545-0895 1.50A-6 1545-0895 1.50A-7 1545-0895 1.50B-1 1545-0895 1.50B-2 1545-0895 1.50B-3 1545-0895 1.50B-4 1545-0895 1.50B-5 1545-0895 1.51-1 1545-0219 1545-0241 1545-0244 1545-0797 1.52-2 1545-0219 1.52-3 1545-0219 1.56(g)-1 1545-1233 1.57-5 1545-0227 1.58-1 1545-0175 1.59-1 1545-1903 1.61-2 1545-0771 1.61-4 1545-0187 1.61-15 1545-0074 1.62-2 1545-1148 1.63-1 1545-0074 1.66-4 1545-1770 1.67-2T 1545-0110 1.67-3 1545-1018 1.67-3T 1545-0118 1.71-1T 1545-0074 1.72-4 1545-0074 1.72-6 1545-0074 1.72-9 1545-0074 1.72-17 1545-0074 1.72-17A 1545-0074 1.72-18 1545-0074 1.74-1 1545-1100 1.79-2 1545-0074 1.79-3 1545-0074 1.83-2 1545-0074 1.83-5 1545-0074 1.83-6 1545-1448 1.103-10 1545-0123 1545-0940 1.103A-2 1545-0720 1.105-4 1545-0074 1.105-5 1545-0074 1.105-6 1545-0074 1.108-4 1545-1539 1.108-5 1545-1421 1.108-7 1545-2155 1.108(i)-1 1545-2147 1.108(i)-2 1545-2147 1.110-1 1545-1661 1.117-5 1545-0869 1.118-2 1545-1639 1.119-1 1545-0067 1.120-3 1545-0057 1.121-1 1545-0072 1.121-2 1545-0072 1.121-3 1545-0072 1.121-4 1545-0072 1545-0091 1.121-5 1545-0072 1.127-2 1545-0768 1.132-2 1545-0771 1.132-5 1545-0771 1.132-9(b) 1545-1676 1.141-1 1545-1451 1.141-12 1545-1451 1.142-2 1545-1451 1.142(f)(4)-1 1545-1730 1.148-0 1545-1098 1.148-1 1545-1098 1.148-2 1545-1098 1545-1347 1.148-3 1545-1098 1545-1347 1.148-4 1545-1098 1545-1347 1.148-5 1545-1098 1545-1490 1.148-6 1545-1098 1545-1451 1.148-7 1545-1098 1545-1347 1.148-8 1545-1098 1.148-11 1545-1098 1545-1347 1.149(e)-1 1545-0720 1.150-1 1545-1347 1.151-1 1545-0074 1.152-3 1545-0071 1545-1783 1.152-4 1545-0074 1.152-4T 1545-0074 1.162-1 1545-0139 1.162-2 1545-0139 1.162-3 1545-0139 1.162-4 1545-0139 1.162-5 1545-0139 1.162-6 1545-0139 1.162-7 1545-0139 1.162-8 1545-0139 1.162-9 1545-0139 1.162-10 1545-0139 1.162-11 1545-0139 1.162-12 1545-0139 1.162-13 1545-0139 1.162-14 1545-0139 1.162-15 1545-0139 1.162-16 1545-0139 1.162-17 1545-0139 1.162-18 1545-0139 1.162-19 1545-0139 1.162-20 1545-0139 1.162-24 1545-2115 1.162-27 1545-1466 1.163-5 1545-0786 1545-1132 1.163-8T 1545-0995 1.163-10T 1545-0074 1.163-13 1545-1491 1.163(d)-1 1545-1421 1.165-1 1545-0177 1.165-2 1545-0177 1.165-3 1545-0177 1.165-4 1545-0177 1.165-5 1545-0177 1.165-6 1545-0177 1.165-7 1545-0177 1.165-8 1545-0177 1.165-9 1545-0177 1.165-10 1545-0177 1.165-11 1545-0074 1545-0177 1545-0786 1.165-12 1545-0786 1.166-1 1545-0123 1.166-2 1545-1254 1.166-4 1545-0123 1.166-10 1545-0123 1.167(a)-5T 1545-1021 1.167(a)-7 1545-0172 1.167(a)-11 1545-0152 1545-0172 1.167(a)-12 1545-0172 1.167(d)-1 1545-0172 1.167(e)-1 1545-0172 1.167(f)-11 1545-0172 1.167(l)-1 1545-0172 1.168(d)-1 1545-1146 1.168(i)-1 1545-1331 1.168-5 1545-0172 1.169-4 1545-0172 1.170-1 1545-0074 1.170-2 1545-0074 1.170-3 1545-0123 1.170A-1 1545-0074 1.170A-2 1545-0074 1.170A-4(A)(b) 1545-0123 1.170A-8 1545-0074 1.170A-9 1545-0052 1545-0074 1.170A-11 1545-0074 1545-0123 1545-1868 1.170A-12 1545-0020 1545-0074 1.170A-13 1545-0074 1545-0754 1545-0908 1545-1431 1.170A-13(f) 1545-1464 1.170A-14 1545-0763 1.170A-15 1545-1953 1.170A-16 1545-1953 1.170A-17 1545-1953 1.170A-18 1545-1953 1.171-4 1545-1491 1.171-5 1545-1491 1.172-1 1545-0172 1.172-13 1545-0863 1.173-1 1545-0172 1.174-3 1545-0152 1.174-4 1545-0152 1.175-3 1545-0187 1.175-6 1545-0152 1.179-2 1545-1201 1.179-3 1545-1201 1.179-5 1545-0172 1545-1201 1.179B-1T 1545-2076 1.179C-1 1545-2103 1.179C-1T 1545-2103 1.180-2 1545-0074 1.181-1 1545-2059 1.181-2 1545-2059 1.181-3 1545-2059 1.182-6 1545-0074 1.183-1 1545-0195 1.183-2 1545-0195 1.183-3 1545-0195 1.183-4 1545-0195 1.190-3 1545-0074 1.194-2 1545-0735 1.194-4 1545-0735 1.195-1 1545-1582 1.197-1T 1545-1425 1.197-2 1545-1671 1.199-6 1545-1966 1.213-1 1545-0074 1.215-1T 1545-0074 1.217-2 1545-0182 1.243-3 1545-0123 1.243-4 1545-0123 1.243-5 1545-0123 1.248-1 1545-0172 1.261-1 1545-1041 1.263(a)-1 1545-2248 1.263(a)-3 1545-2248 1.263(a)-5 1545-1870 1.263(e)-1 1545-0123 1.263A-1 1545-0987 1.263A-1T 1545-0187 1.263A-2 1545-0987 1.263A-3 1545-0987 1.263A-8(b)(2)(iii) 1545-1265 1.263A-9(d)(1) 1545-1265 1.263A-9(f)(1)(ii) 1545-1265 1.263A-9(f)(2)(iv) 1545-1265 1.263A-9(g)(2)(iv)(C) 1545-1265 1.263A-9(g)(3)(iv) 1545-1265 1.265-1 1545-0074 1.265-2 1545-0123 1.266-1 1545-0123 1.267(f)-1 1545-0885 1.268-1 1545-0184 1.274-1 1545-0139 1.274-2 1545-0139 1.274-3 1545-0139 1.274-4 1545-0139 1.274-5 1545-0771 1.274-5A 1545-0139 1545-0771 1.274-5T 1545-0074 1545-0172 1545-0771 1.274-6 1545-0139 1545-0771 1.274-6T 1545-0074 1545-0771 1.274-7 1545-0139 1.274-8 1545-0139 1.279-6 1545-0123 1.280C-4 1545-1155 1.280F-3T 1545-0074 1.280G-1 1545-1851 1.281-4 1545-0123 1.302-4 1545-0074 1.305-3 1545-0123 1.305-5 1545-1438 1.307-2 1545-0074 1.312-15 1545-0172 1.316-1 1545-0123 1.331-1 1545-0074 1.332-4 1545-0123 1.332-6 1545-2019 1.336-2 1545-2125 1.336-4 1545-2125 1.337(d)-1 1545-1160 1.337(d)-2 1545-1160 1545-1774 1.337(d)-4 1545-1633 1.337(d)-5 1545-1672 1.337(d)-6 1545-1672 1.337(d)-7 1545-1672 1.338-2 1545-1658 1.338-5 1545-1658 1.338-10 1545-1658 1.338-11 1545-1990 1.338(h)(10)-1 1545-1658 1.338(i)-1 1545-1990 1.351-3 1545-2019 1.355-5 1545-2019 1.362-2 1545-0123 1.362-4 1545-2247 1.367(a)-1T 1545-0026 1.367(a)-2T 1545-0026 1.367(a)-3 1545-0026 1545-1478 1.367(a)-3T 1545-2183 1.367(a)-6T 1545-0026 1.367(a)-7 1545-2183 1.367(a)-7T 1545-2183 1.367(a)-8 1545-1271 1545-2056 1545-2183 1.367(b)-1 1545-1271 1.367(b)-3T 1545-1666 1.367(d)-1T 1545-0026 1.367(e)-1 1545-1487 1.367(e)-2 1545-1487 1.368-1 1545-1691 1.368-3 1545-2019 1.371-1 1545-0123 1.371-2 1545-0123 1.374-3 1545-0123 1.381(b)-1 1545-0123 1.381(c)(4)-1 1545-0123 1545-0152 1545-0879 1.381(c)(5)-1 1545-0123 1545-0152 1.381(c)(6)-1 1545-0123 1545-0152 1.381(c)(8)-1 1545-0123 1.381(c)(10)-1 1545-0123 1.381(c)(11)-1(k) 1545-0123 1.381(c)(13)-1 1545-0123 1.381(c)(17)-1 1545-0045 1.381(c)(22)-1 1545-1990 1.381(c)(25)-1 1545-0045 1.382-1T 1545-0123 1.382-2 1545-0123 1.382-2T 1545-0123 1.382-3 1545-1281 1545-1345 1.382-4 1545-1120 1.382-6 1545-1381 1.382-8 1545-1434 1.382-9 1545-1120 1545-1260 1545-1275 1545-1324 1.382-11 1545-2019 1.382-91 1545-1260 1545-1324 1.383-1 1545-0074 1545-1120 1.401-1 1545-0020 1545-0197 1545-0200 1545-0534 1545-0710 1.401(a)-11 1545-0710 1.401(a)-20 1545-0928 1.401(a)-31 1545-1341 1.401(a)-50 1545-0710 1.401(a)(9)-1 1545-1573 1.401(a)(9)-3 1545-1466 1.401(a)(9)-4 1545-1573 1.401(a)(9)-6 1545-2234 1.401(a)(31)-1 1545-1341 1.401(b)-1 1545-0197 1.401(f)-1 1545-0710 1.401(k)-1 1545-1039
  • 1545-1069
  • 1545-1669
  • 1545-1930
    •      1.401(k)-2 1545-1669 1.401(k)-3 1545-1669 1.401(k)-4 1545-1669 1.401(m)-3 1545-1699 1.401-14 1545-0710 1.402(c)-2 1545-1341 1.402(f)-1 1545-1341 1545-1632 1.402A-1 1545-1992 1.403(b)-1 1545-0710 1.403(b)-3 1545-0996 1.403(b)-7 1545-1341 1.403(b)-10 1545-2068 1.404(a)-12 1545-0710 1.404A-2 1545-0123 1.404A-6 1545-0123 1.408-2 1545-0390 1.408-5 1545-0747 1.408-6 1545-0203 1545-0390 1.408-7 1545-0119 1.408(q)-1 1545-1841 1.408A-2 1545-1616 1.408A-4 1545-1616 1.408A-5 1545-1616 1.408A-7 1545-1616 1.410(a)-2 1545-0710 1.410(d)-1 1545-0710 1.411(a)-11 1545-1471 1545-1632 1.411(d)-4 1545-1545 1.411(d)-6 1545-1477 1.412(c)(1)-2 1545-0710 1.412(c)(2)-1 1545-0710 1.412(c)(3)-2 1545-0710 1.414(c)-5 1545-0797 1.414(r)-1 1545-1221 1.415-2 1545-0710 1.415-6 1545-0710 1.417(a)(3)-1 1545-0928 1.417(e)-1 1545-1471 1545-1724 1.417(e)-1T 1545-1471 1.419A(f)(6)-1 1545-1795 1.422-1 1545-0820 1.430(f)-1 1545-2095 1.430(g)-1 1545-2095 1.430(h)(2)-1 1545-2095 1.432(e)(9)-1T 1545-2260 1.436-1 1545-2095 1.441-2 1545-1748 1.442-1 1545-0074   1545-0123   1545-0134   1545-0152   1545-0820   1545-1748 1.443-1 1545-0123 1.444-3T 1545-1036 1.444-4 1545-1591 1.446-1 1545-0074 1545-0152 1.446-4(d) 1545-1412 1.448-1(g) 1545-0152 1.448-1(h) 1545-0152 1.448-1(i) 1545-0152 1.448-2 1545-1855 1.448-2T 1545-0152 1545-1855 1.451-1 1545-0091 1.451-4 1545-0123 1.451-6 1545-0074 1.451-7 1545-0074 1.453-1 1545-0152 1.453-2 1545-0152 1.453-8 1545-0152 1545-0228 1.453A-1 1545-0152 1545-1134 1.453A-3 1545-0963 1.454-1 1545-0074 1.455-2 1545-0152 1.455-6 1545-0123 1.456-2 1545-0123 1.456-6 1545-0123 1.456-7 1545-0123 1.457-8 1545-1580 1.458-1 1545-0879 1.458-2 1545-0152 1.460-1 1545-1650 1.460-6 1545-1031 1545-1572 1545-1732 1.461-1 1545-0074 1.461-2 1545-0096 1.461-4 1545-0917 1.461-5 1545-0917 1.463-1T 1545-0916 1.465-1T 1545-0712 1.466-1T 1545-0152 1.466-4 1545-0152 1.468A-3 1545-1269 1545-1378 1545-1511 1.468A-3(h), 1.468A-7, and 1.468A-8(d) 1545-2091 1.468A-4 1545-0954 1.468A-7 1545-0954 1545-1511 1.468A-8 1545-1269 1.468B-1 1545-1631 1.468B-1(j) 1545-1299 1.468B-2(k) 1545-1299 1.468B-2(l) 1545-1299 1.468B-3(b) 1545-1299 1.468B-3(e) 1545-1299 1.468B-5(b) 1545-1299 1.468B-9 1545-1631 1.469-1 1545-1008 1.469-2T 1545-0712 1545-1091 1.469-4T 1545-0985 1545-1037 1.469-7 1545-1244 1.471-2 1545-0123 1.471-5 1545-0123 1.471-6 1545-0123 1.471-8 1545-0123 1.471-11 1545-0123 1545-0152 1.472-1 1545-0042 1545-0152 1.472-2 1545-0152 1.472-3 1545-0042 1.472-5 1545-0152 1.472-8 1545-0028 1545-0042 1545-1767 1.475(a)-4 1545-1945 1.481-4 1545-0152 1.481-5 1545-0152 1.482-1 1545-1364 1.482-4 1545-1364 1.482-7 1545-1364 1545-1794 1.482-9(b) 1545-2149 1.501(a)-1 1545-0056 1545-0057 1.501(c)(3)-1 1545-0056 1.501(c)(9)-5 1545-0047 1.501(c)(17)-3 1545-0047 1.501(e)-1 1545-0814 1.501(r)-3 1545-0047 1.501(r)-4 1545-0047 1.501(r)-6 1545-0047 1.503(c)-1 1545-0047 1545-0052 1.505(c)-1T 1545-0916 1.506-1 1545-2268 1.507-1 1545-0052 1.507-2 1545-0052 1.508-1 1545-0052 1545-0056 1.509(a)-3 1545-0047 1.509(a)-4 1545-2157 1.509(a)-5 1545-0047 1.509(c)-1 1545-0052 1.512(a)-1 1545-0687 1.512(a)-4 1545-0047 1545-0687 1.521-1 1545-0051 1545-0058 1.527-2 1545-0129 1.527-5 1545-0129 1.527-6 1545-0129 1.527-9 1545-0129 1.528-8 1545-0127 1.533-2 1545-0123 1.534-2 1545-0123 1.542-3 1545-0123 1.545-2 1545-0123 1.545-3 1545-0123 1.547-2 1545-0045 1545-0123 1.547-3 1545-0123 1.561-1 1545-0044 1.561-2 1545-0123 1.562-3 1545-0123 1.563-2 1545-0123 1.564-1 1545-0123 1.565-1 1545-0043 1545-0123 1.565-2 1545-0043 1.565-3 1545-0043 1.565-5 1545-0043 1.565-6 1545-0043 1.585-1 1545-0123 1.585-3 1545-0123 1.585-8 1545-1290 1.597-2 1545-1300 1.597-4 1545-1300 1.597-6 1545-1300 1.597-7 1545-1300 1.611-2 1545-0099 1.611-3 1545-0007 1545-0099 1545-1784 1.612-4 1545-0074 1.612-5 1545-0099 1.613-3 1545-0099 1.613-4 1545-0099 1.613-6 1545-0099 1.613-7 1545-0099 1.613A-3 1545-0919 1.613A-3(e) 1545-1251 1.613A-3(l) 1545-0919 1.613A-5 1545-0099 1.613A-6 1545-0099 1.614-2 1545-0099 1.614-3 1545-0099 1.614-5 1545-0099 1.614-6 1545-0099 1.614-8 1545-0099 1.617-1 1545-0099 1.617-3 1545-0099 1.617-4 1545-0099 1.631-1 1545-0007 1.631-2 1545-0007 1.641(b)-2 1545-0092 1.642(c)-1 1545-0092 1.642(c)-2 1545-0092 1.642(c)-5 1545-0074 1.642(c)-6 1545-0020 1545-0074 1545-0092 1.642(g)-1 1545-0092 1.642(i)-1 1545-0092 1.645-1 1545-1578 1.663(b)-2 1545-0092 1.664-1 1545-0196 1.664-1(a)(7) 1545-1536 1.664-1(c) 1545-2101 1.664-2 1545-0196 1.664-3 1545-0196 1.664-4 1545-0020 1545-0196 1.665(a)-0A through 1.665(g)-2A 1545-0192 1.666(d)-1A 1545-0092 1.671-4 1545-1442 1.671-5 1545-1540 1.701-1 1545-0099 1.702-1 1545-0074 1.703-1 1545-0099 1.704-2 1545-1090 1.706-1 1545-0074 1545-0099 1545-0134 1.706-1T 1545-0099 1.706-4(f) 1545-0123 1.707-3(c)(2) 1545-1243 1.707-5(a)(7)(ii) 1545-1243 1.707-6(c) 1545-1243 1.707-8 1545-1243 1.708-1 1545-0099 1.732-1 1545-0099
  • 1545-1588
    •      1.736-1 1545-0074 1.743-1 1545-0074
  • 1545-1588
    •      1.751-1 1545-0074 1545-0099 1545-0941 1.752-2 1545-1905 1.752-5 1545-1090 1.752-7 1545-1843 1.754-1 1545-0099 1.755-1 1545-0099 1.761-2 1545-1338 1.801-1 1545-0123 1545-0128 1.801-3 1545-0123 1.801-5 1545-0128 1.801-8 1545-0128 1.804-4 1545-0128 1.811-2 1545-0128 1.812-2 1545-0128 1.815-6 1545-0128 1.818-4 1545-0128 1.818-5 1545-0128 1.818-8 1545-0128 1.819-2 1545-0128 1.822-5 1545-1027 1.822-6 1545-1027 1.822-8 1545-1027 1.822-9 1545-1027 1.826-1 1545-1027 1.826-2 1545-1027 1.826-3 1545-1027 1.826-4 1545-1027 1.826-6 1545-1027 1.831-3 1545-0123 1.832-4 1545-1227 1.832-5 1545-0123 1.848-2(g)(8) 1545-1287 1.848-2(h)(3) 1545-1287 1.848-2(i)(4) 1545-1287 1.851-2 1545-1010 1.851-4 1545-0123 1.852-1 1545-0123 1.852-4 1545-0123 1545-0145 1.852-6 1545-0123 1545-0144 1.852-7 1545-0074 1.852-9 1545-0074 1545-0123 1545-0144 1545-0145 1545-1783 1.852-11 1545-1094 1.853-3 1545-2035 1.853-4 1545-2035 1.854-2 1545-0123 1.855-1 1545-0123 1.856-2 1545-0123 1545-1004 1.856-6 1545-0123 1.856-7 1545-0123 1.856-8 1545-0123 1.857-8 1545-0123 1.857-9 1545-0074 1.858-1 1545-0123 1.860-2 1545-0045 1.860-4 1545-0045 1545-1054 1545-1057 1.860E-1 1545-1675 1.860E-2(a)(5) 1545-1276 1.860E-2(a)(7) 1545-1276 1.860E-2(b)(2) 1545-1276 1.860G-2 1545-2110 1.861-2 1545-0089 1.861-3 1545-0089 1.861-4 1545-1900 1.861-8 1545-0126 1.861-8(e)(6) and (g) 1545-1224 1.861-9T 1545-0121 1545-1072 1.861-18 1545-1594 1.863-1 1545-1476 1.863-3 1545-1476 1545-1556 1.863-3A 1545-0126 1.863-4 1545-0126 1.863-7 1545-0132 1.863-8 1545-1718 1.863-9 1545-1718 1.864-4 1545-0126 1.871-1 1545-0096 1.871-6 1545-0795 1.871-7 1545-0089 1.871-10 1545-0089 1545-0165 1.874-1 1545-0089 1.881-4 1545-1440 1.882-4 1545-0126 1.883-0 1545-1677 1.883-1 1545-1677 1.883-2 1545-1677 1.883-3 1545-1677 1.883-4 1545-1677 1.883-5 1545-1677 1.884-0 1545-1070 1.884-1 1545-1070 1.884-2 1545-1070 1.884-2T 1545-0126 1545-1070 1.884-4 1545-1070 1.884-5 1545-1070 1.892-1T 1545-1053 1.892-2T 1545-1053 1.892-3T 1545-1053 1.892-4T 1545-1053 1.892-5T 1545-1053 1.892-6T 1545-1053 1.892-7T 1545-1053 1.897-2 1545-0123 1545-0902 1.897-3 1545-0123 1.897-5T 1545-0902 1.897-6T 1545-0902 1.901-2 1545-0746 1.901-2A 1545-0746 1.901-3 1545-0122 1.902-1 1545-0122 1545-1458 1.904-1 1545-0121 1545-0122 1.904-2 1545-0121 1545-0122 1.904-3 1545-0121 1.904-4 1545-0121 1.904-5 1545-0121 1.904-7 1545-2104 1.904-7T 1545-2104 1.904(f)-1 1545-0121 1545-0122 1.904(f)-2 1545-0121 1.904(f)-3 1545-0121 1.904(f)-4 1545-0121 1.904(f)-5 1545-0121 1.904(f)-6 1545-0121 1.904(f)-7 1545-1127 1.905-2 1545-0122 1.905-3T 1545-1056 1.905-4T 1545-1056 1.905-5T 1545-1056 1.911-1 1545-0067 1545-0070 1.911-2 1545-0067 1545-0070 1.911-3 1545-0067 1545-0070 1.911-4 1545-0067 1545-0070 1.911-5 1545-0067 1545-0070 1.911-6 1545-0067 1545-0070 1.911-7 1545-0067 1545-0070 1.913-13 1545-0067 1.921-1T 1545-0190 1545-0884 1545-0935 1545-0939 1.921-2 1545-0884 1.927(a)-1T 1545-0935 1.927(d)-2T 1545-0935 1.931-1 1545-0074 1545-0123 1.934-1 1545-0782 1.935-1 1545-0074 1545-0087 1545-0803 1.936-1 1545-0215 1545-0217 1.936-4 1545-0215 1.936-5 1545-0704 1.936-6 1545-0215 1.936-7 1545-0215 1.936-10(c) 1545-1138 1.937-1 1545-1930 1.952-2 1545-0126 1.953-2 1545-0126 1.954-1 1545-1068 1.954-2 1545-1068 1.955-2 1545-0123 1.955-3 1545-0123 1.955A-2 1545-0755 1.955A-3 1545-0755 1.956-1 1545-0704 1.956-2 1545-0704 1.959-1 1545-0704 1.959-2 1545-0704 1.960-1 1545-0122 1.962-2 1545-0704 1.962-3 1545-0704 1.964-1 1545-0126 1545-0704 1545-1072 1545-2104 1.964-3 1545-0126 1.970-2 1545-0126 1.985-2 1545-1051 1545-1131 1.985-3 1545-1051 1.987-1 1545-2265 1.987-3 1545-2265 1.987-9 1545-2265 1.987-10 1545-2265 1.988-0 1545-1131 1.988-1 1545-1131 1.988-2 1545-1131 1.988-3 1545-1131 1.988-4 1545-1131 1.988-5 1545-1131 1.988-6 1545-1831 1.992-1 1545-0190 1545-0938 1.992-2 1545-0190 1545-0884 1545-0938 1.992-3 1545-0190 1545-0938 1.992-4 1545-0190 1545-0938 1.993-3 1545-0938 1.993-4 1545-0938 1.994-1 1545-0938 1.995-5 1545-0938 1.1001-1 1545-1902 1.1012-1 1545-0074 1545-1139 1.1014-4 1545-0184 1.1015-1 1545-0020 1.1017-1 1545-1539 1.1031(d)-1T 1545-1021 1.1033(a)-2 1545-0184 1.1033(g)-1 1545-0184 1.1039-1 1545-0184 1.1041-1T 1545-0074 1.1041-2 1545-1751 1.1042-1T 1545-0916 1.1044(a)-1 1545-1421 1.1045-1 1545-1893 1.1060-1 1545-1658
  • 1545-1990
    •      1.1071-1 1545-0184 1.1071-4 1545-0184 1.1081-4 1545-0028 1545-0046 1545-0123 1.1081-11 1545-2019 1.1082-1 1545-0046 1.1082-2 1545-0046 1.1082-3 1545-0046 1545-0184 1.1082-4 1545-0046 1.1082-5 1545-0046 1.1082-6 1545-0046 1.1083-1 1545-0123 1.1092(b)-1T 1545-0644 1.1092(b)-2T 1545-0644 1.1092(b)-3T 1545-0644 1.1092(b)-4T 1545-0644 1.1092(b)-5T 1545-0644 1.1211-1 1545-0074 1.1212-1 1545-0074 1.1221-2 1545-1480 1.1231-1 1545-0177 1545-0184 1.1231-2 1545-0177 1545-0184 1.1231-2 1545-0074 1.1232-3 1545-0074 1.1237-1 1545-0184 1.1239-1 1545-0091 1.1242-1 1545-0184 1.1243-1 1545-0123 1.1244(e)-1 1545-0123 1545-1447 1.1245-1 1545-0184 1.1245-2 1545-0184 1.1245-3 1545-0184 1.1245-4 1545-0184 1.1245-5 1545-0184 1.1245-6 1545-0184 1.1248-7 1545-0074 1.1248(f)-2 1545-2183 1.1248(f)-3T 1545-2183 1.1250-1 1545-0184 1.1250-2 1545-0184 1.1250-3 1545-0184 1.1250-4 1545-0184 1.1250-5 1545-0184 1.1251-1 1545-0184 1.1251-2 1545-0074 1545-0184 1.1251-3 1545-0184 1.1251-4 1545-0184 1.1252-1 1545-0184 1.1252-2 1545-0184 1.1254-1(c)(3) 1545-1352 1.1254-4 1545-1493 1.1254-5(d)(2) 1545-1352 1.1258-1 1545-1452 1.1272-3 1545-1353 1.1273-2(f)(9) 1545-1353 1.1273-2(h)(2) 1545-1353 1.1274-3(d) 1545-1353 1.1274-5(b) 1545-1353 1.1274A-1(c) 1545-1353 1.1275-2 1545-1450 1.1275-3 1545-0887 1545-1353 1545-1450 1.1275-4 1545-1450 1.1275-6 1545-1450 1.1287-1 1545-0786 1.1291-9 1545-1507 1.1291-10 1545-1304 1545-1507 1.1294-1T 1545-1002 1545-1028 1.1295-1 1545-1555 1.1295-3 1545-1555 1.1298-3 1545-1507 1.1301-1 1545-1662 1.1311(a)-1 1545-0074 1.1361-1 1545-0731 1545-1591 1545-2114 1.1361-3 1545-1590 1.1361-5 1545-1590 1.1362-1 1545-1308 1.1362-2 1545-1308 1.1362-3 1545-1308 1.1362-4 1545-1308 1.1362-5 1545-1308 1.1362-6 1545-1308 1.1362-7 1545-1308 1.1362-8 1545-1590 1.1363-2 1545-1906 1.1366-1 1545-1613 1.1367-1(f) 1545-1139 1.1368-1(f)(2) 1545-1139 1.1368-1(f)(3) 1545-1139 1.1368-1(f)(4) 1545-1139 1.1368-1(g)(2) 1545-1139 1.1374-1A 1545-0130 1.1377-1 1545-1462 1.1378-1 1545-1748 1.1383-1 1545-0074 1.1385-1 1545-0074 1545-0098 1.1388-1 1545-0118 1545-0123 1.1397E-1 1545-1908 1.1398-1 1545-1375 1.1398-2 1545-1375 1.1402(a)-2 1545-0074 1.1402(a)-5 1545-0074 1.1402(a)-11 1545-0074 1.1402(a)-15 1545-0074 1.1402(a)-16 1545-0074 1.1402(b)-1 1545-0171 1.1402(c)-2 1545-0074 1.1402(e)(1)-1 1545-0074 1.1402(e)(2)-1 1545-0074 1.1402(e)-1A 1545-0168 1.1402(e)-2A 1545-0168 1.1402(e)-3A 1545-0168 1.1402(e)-4A 1545-0168 1.1402(e)-5A 1545-0168 1.1402(f)-1 1545-0074 1.1402(h)-1 1545-0064 1.1411-10(g) 1545-2227 1.1441-1 1545-1484 1.1441-2 1545-0795 1.1441-3 1545-0165 1545-0795 1.1441-4 1545-1484 1.1441-5 1545-0096 1545-0795 1545-1484 1.1441-6 1545-0055 1545-0795 1545-1484 1.1441-7 1545-0795 1.1441-8 1545-1053 1545-1484 1.1441-9 1545-1484 1.1443-1 1545-0096 1.1445-1 1545-0902 1.1445-2 1545-0902 1545-1060 1545-1797 1.1445-3 1545-0902 1545-1060 1545-1797 1.1445-4 1545-0902 1.1445-5 1545-0902 1.1445-6 1545-0902 1545-1060 1.1445-7 1545-0902 1.1445-8 1545-0096 1.1445-9T 1545-0902 1.1445-10T 1545-0902 1.1446-1 1545-1934 1.1446-3 1545-1934 1.1446-4 1545-1934 1.1446-5 1545-1934 1.1446-6 1545-1934 1.1451-1 1545-0054 1.1451-2 1545-0054 1.1461-1 1545-0054 1545-0055 1545-0795 1545-1484 1.1461-2 1545-0054 1545-0055 1545-0096 1545-0795 1.1462-1 1545-0795 1.1502-5 1545-0257 1.1502-9 1545-1634 1.1502-9A 1545-0121 1.1502-13 1545-0123 1545-0885 1545-1161 1545-1433 1.1502-16 1545-0123 1.1502-18 1545-0123 1.1502-19 1545-0123 1545-1774 1.1502-20 1545-1774 1.1502-21 1545-1237 1.1502-21T 1545-2171 1.1502-31 1545-1344 1.1502-32 1545-1344 1545-1774 1.1502-33 1545-1344 1.1502-35 1545-1828 1.1502-36 1545-2096 1.1502-47 1545-0123 1.1502-75 1545-0025 1545-0123 1545-0133 1545-0152 1.1502-76 1545-1344 1.1502-76T 1545-2019 1.1502-77 1545-1699 1.1502-77A 1545-0123   1545-1046 1.1502-77B 1545-1699 1.1502-78 1545-0582 1.1502-95 1545-1218 1.1502-95A 1545-1218 1.1502-96 1545-1218 1.1503-2 1545-1583 1.1503-2A 1545-1083 1.1503(d)-1 1545-1946 1.1503(d)-3 1545-1946 1.1503(d)-4 1545-1946 1.1503(d)-5 1545-1946 1.1503(d)-6 1545-1946 1.1552-1 1545-0123 1.1561-3 1545-0123 1.1563-1 1545-0123 1545-0797 1545-2019 1.1563-3 1545-0123 1.5000A-3 1545-0074 1.5000A-4 1545-0074 1.5000C-2 1545-0096 1545-2263 1.5000C-3 1545-0096 1545-2263 1.5000C-4 1545-1223 1545-0074 1.6001-1 1545-0058 1545-0074 1545-0099 1545-0123 1545-0865 1.6011-1 1545-0055 1545-0074 1545-0085 1545-0089 1545-0090 1545-0091 1545-0096 1545-0121 1545-0458 1545-0666 1545-0675 1545-0908 1.6011-2 1545-0055 1545-0938 1.6011-3 1545-0238 1545-0239 1.6011-4 1545-1685 1.6012-1 1545-0067 1545-0074 1545-0085 1545-0089 1545-0675 1.6012-2 1545-0047 1545-0051 1545-0067 1545-0123 1545-0126 1545-0128 1545-0130 1545-0175 1545-0687 1545-0890 1545-1023 1545-1027 1.6012-3 1545-0047 1545-0067 1545-0092 1545-0196 1545-0687 1.6012-4 1545-0067 1.6012-5 1545-0067 1545-0936 1545-0967 1545-0970 1545-0991 1545-1023 1545-1033 1545-1079 1.6012-6 1545-0067 1545-0089 1545-0129 1.6013-1 1545-0074 1.6013-2 1545-0091 1.6013-6 1545-0074 1.6013-7 1545-0074 1.6015-5 1545-1719 1.6015(a)-1 1545-0087 1.6015(b)-1 1545-0087 1.6015(d)-1 1545-0087 1.6015(e)-1 1545-0087 1.6015(f)-1 1545-0087 1.6015(g)-1 1545-0087 1.6015(h)-1 1545-0087 1.6015(i)-1 1545-0087 1.6017-1 1545-0074 1545-0087 1545-0090 1.6031(a)-1 1545-1583 1.6031(b)-1T 1545-0099 1.6031(c)-1T 1545-0099 1.6032-1 1545-0099 1.6033-2 1545-0047 1545-0049 1545-0052 1545-0092 1545-0687 1545-1150 1545-2117 1.6033-3 1545-0052 1.6034-1 1545-0092 1545-0094 1.6035-2 1545-0704 1.6037-1 1545-0130 1545-1023 1.6038-2 1545-1617 1545-2020 1.6038-3 1545-1617 1.6038A-2 1545-1191 1.6038A-3 1545-1191 1545-1440 1.6038B-1 1545-1617 1545-2183 1.6038B-1T 1545-0026 1545-2183 1.6038B-2 1545-1617 1.6039-2 1545-0820 1.6041-1 1545-0008 1545-0108 1545-0112 1545-0115 1545-0120 1545-0295 1545-0350 1545-0367 1545-0387 1545-0441 1545-0957 1545-1705 1.6041-2 1545-0008 1545-0119 1545-0350 1545-0441 1545-1729 1.6041-3 1545-1148 1.6041-4 1545-0115 1545-0295 1545-0367 1545-0387 1545-0957 1.6041-5 1545-0295 1545-0367 1545-0387 1545-0957 1.6041-6 1545-0008 1545-0115 1.6041-7 1545-0112 1545-0295 1545-0350 1545-0367 1545-0387 1545-0441 1545-0957 1.6042-1 1545-0110 1.6042-2 1545-0110 1545-0295 1545-0367 1545-0387 1545-0957 1.6042-3 1545-0295 1545-0367 1545-0387 1545-0957 1.6042-4 1545-0110 1.6043-1 1545-0041 1.6043-2 1545-0041 1545-0110 1545-0295 1545-0387 1.6043-3 1545-0047 1.6044-1 1545-0118 1.6044-2 1545-0118 1.6044-3 1545-0118 1.6044-4 1545-0118 1.6044-5 1545-0118 1.6045-1 1545-0715 1545-1705 1.6045-1(c)(3)(xi)(C) 1545-2186 1.6045-1(n)(5) 1545-2186 1.6045A-1 1545-2186 1.6045-2 1545-0115 1.6045-4 1545-1085 1.6046-1 1545-0704 1545-0794 1545-1317 1.6046-2 1545-0704 1.6046-3 1545-0704 1.6046A 1545-1646 1.6047-1 1545-0119 1545-0295 1545-0387 1.6047-2 1545-2234 1.6049-1 1545-0112 1545-0117 1545-0295 1545-0367 1545-0387 1545-0597 1545-0957 1.6049-2 1545-0117 1.6049-3 1545-0117 1.6049-4 1545-0096 1545-0112 1545-0117 1545-1018 1545-1050 1.6049-5 1545-0096 1545-0112 1545-0117 1.6049-6 1545-0096 1.6049-7 1545-1018 1.6050A-1 1545-0115 1.6050B-1 1545-0120 1.6050D-1 1545-0120 1545-0232 1.6050E-1 1545-0120 1.6050H-1 1545-0901 1545-1380 1.6050H-2 1545-0901 1545-1339 1545-1380 1.6050I-2 1545-1449 1.6050J-1T 1545-0877 1.6050K-1 1545-0941 1.6050S-1 1545-1678 1.6050S-2 1545-1729 1.6050S-3 1545-1678 1.6050S-4 1545-1729 1.6052-1 1545-0008 1.6052-2 1545-0008 1.6055-1 1545-2252 1.6055-2 1545-2252 1.6060-1 1545-0074 1.6060-1(a)(1) 1545-1231 1.6061-1 1545-0123 1.6062-1 1545-0123 1.6063-1 1545-0123 1.6065-1 1545-0123 1.6071-1 1545-0123 1545-0810 1.6072-1 1545-0074 1.6072-2 1545-0123 1545-0807 1.6073-1 1545-0087 1.6073-2 1545-0087 1.6073-3 1545-0087 1.6073-4 1545-0087 1.6074-1 1545-0123 1.6074-2 1545-0123 1.6081-1 1545-0066 1545-0148 1545-0233 1545-1057 1545-1081 1.6081-2 1545-0148 1545-1036 1545-1054 1.6081-3 1545-0233 1.6081-4 1545-0188 1545-1479 1.6081-6 1545-0148 1545-1054 1.6081-7 1545-0148 1545-1054 1.6091-3 1545-0089 1.6107-1 1545-0074 1545-1231 1.6109-1 1545-0074 1.6109-2 1545-2176 1.6115-1 1545-1464 1.6151-1 1545-0074 1.6153-1 1545-0087 1.6153-4 1545-0087 1.6161-1 1545-0087 1.6162-1 1545-0087 1.6164-1 1545-0135 1.6164-2 1545-0135 1.6164-3 1545-0135 1.6164-5 1545-0135 1.6164-6 1545-0135 1.6164-7 1545-0135 1.6164-8 1545-0135 1.6164-9 1545-0135 1.6302-1 1545-0257 1.6302-2 1545-0098 1545-0257 1.6411-1 1545-0098 1545-0135 1545-0582 1.6411-2 1545-0098 1545-0582 1.6411-3 1545-0098 1545-0582 1.6411-4 1545-0582 1.6414-1 1545-0096 1.6425-1 1545-0170 1.6425-2 1545-0170 1.6425-3 1545-0170 1.6654-1 1545-0087 1545-0140 1.6654-2 1545-0087 1.6654-3 1545-0087 1.6655(e)-1 1545-1421 1.6662-3(c) 1545-0889 1.6662-4(e) and (f) 1545-0889 1.6662-6 1545-1426 1.6694-1 1545-0074 1.6694-2 1545-0074 1.6694-2(c) 1545-1231 1.6694-2(c)(3) 1545-1231 1.6694-3(e) 1545-1231 1.6695-1 1545-0074 1545-1385 1.6696-1 1545-0074 1545-0240 1.6851-1 1545-0086 1545-0138 1.6851-2 1545-0086 1545-0138 1.7476-1 1545-0197 1.7476-2 1545-0197 1.7519-2T 1545-1036 1.7520-1 1545-1343 1.7520-2 1545-1343 1.7520-3 1545-1343 1.7520-4 1545-1343 1.7701(l)-3 1545-1642 1.7872-15 1545-1792 1.9100-1 1545-0074 1.9101-1 1545-0008 2.1-4 1545-0123 2.1-5 1545-0123 2.1-6 1545-0123 2.1-10 1545-0123 2.1-11 1545-0123 2.1-12 1545-0123 2.1-13 1545-0123 2.1-20 1545-0123 2.1-22 1545-0123 2.1-26 1545-0123 3.2 1545-0123 4.954-1 1545-1068 4.954-2 1545-1068 5.6411-1 1545-0042 1545-0074 1545-0098 1545-0129 1545-0172 1545-0582 1545-0619 5c.44F-1 1545-0619 5c.128-1 1545-0123 5c.305-1 1545-0110 5c.442-1 1545-0152 5f.103-1 1545-0720 5f.6045-1 1545-0715 6a.103A-2 1545-0123 1545-0720 6a.103A-3 1545-0720 7.465-1 1545-0712 7.465-2 1545-0712 7.465-3 1545-0712 7.465-4 1545-0712 7.465-5 1545-0712 7.936-1 1545-0217 7.999-1 1545-0216 7.6039A-1 1545-0015 7.6041-1 1545-0115 11.410-1 1545-0710 11.412(c)-7 1545-0710 11.412(c)-11 1545-0710 12.7 1545-0190 12.8 1545-0191 12.9 1545-0195 14a.422A-1 1545-0123 15A.453-1 1545-0228 16A.126-2 1545-0074 16A.1255-1 1545-0184 16A.1255-2 1545-0184 18.1371-1 1545-0130 18.1378-1 1545-0130 18.1379-1 1545-0130 18.1379-2 1545-0130 20.2010-2 1545-0015 20.2011-1 1545-0015 20.2014-5 1545-0015 1545-0260 20.2014-6 1545-0015 20.2016-1 1545-0015 20.2031-2 1545-0015 20.2031-3 1545-0015 20.2031-4 1545-0015 20.2031-6 1545-0015 20.2031-7 1545-0020 20.2031-10 1545-0015 20.2032-1 1545-0015 20.2032A-3 1545-0015 20.2032A-4 1545-0015 20.2032A-8 1545-0015 20.2039-4 1545-0015 20.2051-1 1545-0015 20.2053-3 1545-0015 20.2053-9 1545-0015 20.2053-10 1545-0015 20.2055-1 1545-0015 20.2055-2 1545-0015 1545-0092 20.2055-3 1545-0015 20.2056(b)-4 1545-0015 20.2056(b)-7 1545-0015 1545-1612 20.2056A-2 1545-1443 20.2056A-3 1545-1360 20.2056A-4 1545-1360 20.2056A-10 1545-1360 20.2106-1 1545-0015 20.2106-2 1545-0015 20.2204-1 1545-0015 20.2204-2 1545-0015 20.6001-1 1545-0015 20.6011-1 1545-0015 20.6018-1 1545-0015 1545-0531 20.6018-2 1545-0015 20.6018-3 1545-0015 20.6018-4 1545-0015 1545-0022 20.6036-2 1545-0015 20.6060-1(a)(1) 1545-1231 20.6061-1 1545-0015 20.6065-1 1545-0015 20.6075-1 1545-0015 20.6081-1 1545-0015 1545-0181 1545-1707 20.6091-1 1545-0015 20.6107-1 1545-1231 20.6161-1 1545-0015 1545-0181 20.6161-2 1545-0015 1545-0181 20.6163-1 1545-0015 20.6166-1 1545-0181 20.6166A-1 1545-0015 20.6166A-3 1545-0015 20.6324A-1 1545-0754 20.7520-1 1545-1343 20.7520-2 1545-1343 20.7520-3 1545-1343 20.7520-4 1545-1343 22.0 1545-0015 25.2511-2 1545-0020 25.2512-2 1545-0020 25.2512-3 1545-0020 25.2512-5 1545-0020 25.2512-9 1545-0020 25.2513-1 1545-0020 25.2513-2 1545-0020 1545-0021 25.2513-3 1545-0020 25.2518-2 1545-0959 25.2522(a)-1 1545-0196 25.2522(c)-3 1545-0020 1545-0196 25.2523(a)-1 1545-0020 1545-0196 25.2523(f)-1 1545-0015 25.2701-2 1545-1241 25.2701-4 1545-1241 25.2701-5 1545-1273 25.2702-5 1545-1485 25.2702-6 1545-1273 25.6001-1 1545-0020 1545-0022 25.6011-1 1545-0020 25.6019-1 1545-0020 25.6019-2 1545-0020 25.6019-3 1545-0020 25.6019-4 1545-0020 25.6060-1(a)(1) 1545-1231 25.6061-1 1545-0020 25.6065-1 1545-0020 25.6075-1 1545-0020 25.6081-1 1545-0020 25.6091-1 1545-0020 25.6091-2 1545-0020 25.6107-1 1545-1231 25.6151-1 1545-0020 25.6161-1 1545-0020 25.7520-1 1545-1343 25.7520-2 1545-1343 25.7520-3 1545-1343 25.7520-4 1545-1343 26.2601-1 1545-0985 26.2632-1 1545-0985 1545-1892 26.2642-1 1545-0985 26.2642-2 1545-0985 26.2642-3 1545-0985 26.2642-4 1545-0985 26.2642-6 1545-1902 26.2652-2 1545-0985 26.2654-1 1545-1902 26.2662-1 1545-0015 1545-0985 26.2662-2 1545-0985 26.6060-1(a)(1) 1545-1231 26.6107-1 1545-1231 31.3102-3 1545-0029 1545-0059 1545-0065 31.3121(b)(19)-1 1545-0029 31.3121(d)-1 1545-0004 31.3121(i)-1 1545-0034 31.3121(r)-1 1545-0029 31.3121(s)-1 1545-0029 31.3121(v)(2)-1 1545-1643 31.3302(a)-2 1545-0028 31.3302(a)-3 1545-0028 31.3302(b)-2 1545-0028 31.3302(e)-1 1545-0028 31.3306(c)(18)-1 1545-0029 31.3401(a)-1 1545-0029 31.3401(a)(6) 1545-1484 31.3401(a)(6)-1 1545-0029 1545-0096 1545-0795 31.3401(a)(7)-1 1545-0029 31.3401(a)(8)(A)-1 . 1545-0029 1545-0666 31.3401(a)(8)(C)-1 . 1545-0029 31.3401(a)(15)-1 1545-0182 31.3401(c)-1 1545-0004 31.3402(b)-1 1545-0010 31.3402(c)-1 1545-0010 31.3402(f)(1)-1 1545-0010 31.3402(f)(2)-1 1545-0010 1545-0410 31.3402(f)(3)-1 1545-0010 31.3402(f)(4)-1 1545-0010 31.3402(f)(4)-2 1545-0010 31.3402(f)(5)-1 1545-0010 1545-1435 31.3402(h)(1)-1 1545-0029 31.3402(h)(3)-1 1545-0010 1545-0029 31.3402(h)(4)-1 1545-0010 31.3402(i)-(1) 1545-0010 31.3402(i)-(2) 1545-0010 31.3402(k)-1 1545-0065 31.3402(l)-(1) 1545-0010 31.3402(m)-(1) 1545-0010 31.3402(n)-(1) 1545-0010 31.3402(o)-2 1545-0415 31.3402(o)-3 1545-0008 1545-0010 1545-0415 1545-0717 31.3402(p)-1 1545-0415 1545-0717 31.3402(q)-1 1545-0238 1545-0239 31.3404-1 1545-0029 31.3405(c)-1 1545-1341 31.3406(a)-1 1545-0112 31.3406(a)-2 1545-0112 31.3406(a)-3 1545-0112 31.3406(a)-4 1545-0112 31.3406(b)(2)-1 1545-0112 31.3406(b)(2)-2 1545-0112 31.3406(b)(2)-3 1545-0112 31.3406(b)(2)-4 1545-0112 31.3406(b)(2)-5 1545-0112 31.3406(b)(3)-1 1545-0112 31.3406(b)(3)-2 1545-0112 31.3406(b)(3)-3 1545-0112 31.3406(b)(3)-4 1545-0112 31.3406(b)(4)-1 1545-0112 31.3406(c)-1 1545-0112 31.3406(d)-1 1545-0112 31.3406(d)-2 1545-0112 31.3406(d)-3 1545-0112 31.3406(d)-4 1545-0112 31.3406(d)-5 1545-0112 31.3406(e)-1 1545-0112 31.3406(f)-1 1545-0112 31.3406(g)-1 1545-0096 1545-0112 1545-1819 31.3406(g)-2 1545-0112 31.3406(g)-3 1545-0112 31.3406(h)-1 1545-0112 31.3406(h)-2 1545-0112 31.3406(h)-3 1545-0112 31.3406(i)-1 1545-0112 31.3501(a)-1T 1545-0771 31.3503-1 1545-0024 31.3504-1 1545-0029 31.3511-1 1545-2266 31.6001-1 1545-0798 31.6001-2 1545-0034 1545-0798 31.6001-3 1545-0798 31.6001-4 1545-0028 31.6001-5 1545-0798 31.6001-6 1545-0029 1459-0798 31.6011(a)-1 1545-0029 1545-0034 1545-0035 1545-0059 1545-0074 1545-0256 1545-0718 1545-2097 31.6011(a)-2 1545-0001 1545-0002 31.6011(a)-3 1545-0028 31.6011(a)-3A 1545-0955 31.6011(a)-4 1545-0034 1545-0035 1545-0718 1545-1413 1545-2097 31.6011(a)-5 1545-0028 1545-0718 1545-2097 31.6011(a)-6 1545-0028 31.6011(a)-7 1545-0074 31.6011(a)-8 1545-0028 31.6011(a)-9 1545-0028 31.6011(a)-10 1545-0112 31.6011(b)-1 1545-0003 31.6011(b)-2 1545-0029 31.6051-1 1545-0008 1545-0182 1545-0458 1545-1729 31.6051-2 1545-0008 31.6051-3 1545-0008 31.6053-1 1545-0029 1545-0062 1545-0064 1545-0065 1545-1603 31.6053-2 1545-0008 31.6053-3 1545-0065 1545-0714 31.6053-4 1545-0065 1545-1603 31.6060-1(a)(1) 1545-1231 31.6065(a)-1 1545-0029 31.6071(a)-1 1545-0001 1545-0028 1545-0029 31.6071(a)-1A 1545-0955 31.6081(a)-1 1545-0008 1545-0028 31.6091-1 1545-0028 1545-0029 31.6107-1 1545-1231 31.6157-1 1545-0955 31.6205-1 1545-0029 1545-2097 31.6301(c)-1AT 1545-0035 1545-0112 1545-0257 31.6302-1 1545-1413 31.6302-2 1545-1413 31.6302-3 1545-1413 31.6302-4 1545-1413 31.6302(c)-2 1545-0001 1545-0257 31.6302(c)-2A 1545-0955 31.6302(c)-3 1545-0257 31.6402(a)-2 1545-0256 1545-2097 31.6413(a)-1 1545-0029 1545-2097 31.6413(a)-2 1545-0029 1545-0256 1545-2097 31.6413(c)-1 1545-0029 1545-0171 31.6414-1 1545-0029 1545-2097 32.1 1545-0029 1545-0415 32.2 1545-0029 35a.3406-2 1545-0112 35a.9999-5 1545-0029 36.3121(l)(1)-1 1545-0137 36.3121(l)(1)-2 1545-0137 36.3121(l)(3)-1 1545-0123 36.3121(1)(7)-1 1545-0123 36.3121(1)(10)-1 1545-0029 36.3121(1)(10)-3 1545-0029 36.3121(1)(10)-4 1545-0257 40.6060-1(a)(1) 1545-1231 40.6107-1 1545-1231 40.6302(c)-3(b)(2)(ii) 1545-1296 40.6302(c)-3(b)(2)(iii) 1545-1296 40.6302(c)-3(e) 1545-1296 40.6302(c)-3(f)(2)(ii) 1545-1296 41.4481-1 1545-0143 41.4481-2 1545-0143 41.4483-3 1545-0143 41.6001-1 1545-0143 41.6001-2 1545-0143 41.6001-3 1545-0143 41.6060-1(a)(1) 1545-1231 41.6071(a)-1 1545-0143 41.6081(a)-1 1545-0143 41.6091-1 1545-0143 41.6107-1 1545-1231 41.6109-1 1545-0143 41.6151(a)-1 1545-0143 41.6156-1 1545-0143 41.6161(a)(1)-1 1545-0143 44.4401-1 1545-0235 44.4403-1 1545-0235 44.4412-1 1545-0236 44.4901-1 1545-0236 44.4905-1 1545-0236 44.4905-2 1545-0236 44.6001-1 1545-0235 44.6011(a)-1 1545-0235 1545-0236 44.6060-1(a)(1) 1545-1231 44.6071-1 1545-0235 44.6091-1 1545-0235 44.6107-1 1545-1231 44.6151-1 1545-0235 44.6419-1 1545-0235 44.6419-2 1545-0235 46.4371-4 1545-0023 46.4374-1 1545-0023 46.4375-1 1545-2238 46.4376-1 1545-2238 46.4701-1 1545-0023 1545-0257 48.4041-4 1545-0023 48.4041-5 1545-0023 48.4041-6 1545-0023 48.4041-7 1545-0023 48.4041-9 1545-0023 48.4041-10 1545-0023 48.4041-11 1545-0023 48.4041-12 1545-0023 48.4041-13 1545-0023 48.4041-19 1545-0023 48.4041-20 1545-0023 48.4041-21 1545-1270 48.4042-2 1545-0023 48.4052-1 1545-1418 48.4061(a)-1 1545-0023 48.4061(a)-2 1545-0023 48.4061(b)-3 1545-0023 48.4064-1 1545-0014 1545-0242 48.4071-1 1545-0023 48.4073-1 1545-0023 48.4073-3 1545-0023 1545-1074 1545-1087 48.4081-2 1545-1270
  • 1545-1418
    •      48.4081-3 1545-1270 1545-1418 1545-1897 48.4081-4(b)(2)(ii) 1545-1270 48.4081-4(b)(3)(i) 1545-1270 48.4081-4(c) 1545-1270 48.4081-6(c)(1)(ii) 1545-1270 48.4081-7 1545-1270
  • 1545-1418
    •      48.4082-1T 1545-1418 48.4082-2 1545-1418 48.4082-6 1545-1418 48.4082-7 1545-1418 48.4101-1 1545-1418 48.4101-1T 1545-1418 48.4101-2 1545-1418 48.4161(a)-1 1545-0723 48.4161(a)-2 1545-0723 48.4161(a)-3 1545-0723 48.4161(b)-1 1545-0723 48.4216(a)-2 1545-0023 48.4216(a)-3 1545-0023 48.4216(c)-1 1545-0023 48.4221-1 1545-0023 48.4221-2 1545-0023 48.4221-3 1545-0023 48.4221-4 1545-0023 48.4221-5 1545-0023 48.4221-6 1545-0023 48.4221-7 1545-0023 48.4222(a)-1 1545-0014 1545-0023 48.4223-1 1545-0023 1545-0257 1545-0723 48.6302(c)-1 1545-0023 1545-0257 48.6412-1 1545-0723 48.6416(a)-1 1545-0023 1545-0723 48.6416(a)-2 1545-0723 48.6416(a)-3 1545-0723 48.6416(b)(1)-1 1545-0723 48.6416(b)(1)-2 1545-0723 48.6416(b)(1)-3 1545-0723 48.6416(b)(1)-4 1545-0723 48.6416(b)(2)-1 1545-0723 48.6416(b)(2)-2 1545-0723 48.6416(b)(2)-3 1545-0723 1545-1087 48.6416(b)(2)-4 1545-0723 48.6416(b)(3)-1 1545-0723 48.6416(b)(3)-2 1545-0723 48.6416(b)(3)-3 1545-0723 48.6416(b)(4)-1 1545-0723 48.6416(b)(5)-1 1545-0723 48.6416(c)-1 1545-0723 48.6416(e)-1 1545-0023 1545-0723 48.6416(f)-1 1545-0023 1545-0723 48.6416(g)-1 1545-0723 48.6416(h)-1 1545-0723 48.6420(c)-2 1545-0023 48.6420(f)-1 1545-0023 48.6420-1 1545-0162 1545-0723 48.6420-2 1545-0162 1545-0723 48.6420-3 1545-0162 1545-0723 48.6420-4 1545-0162 1545-0723 48.6420-5 1545-0162 1545-0723 48.6420-6 1545-0162 1545-0723 48.6421-0 1545-0162 1545-0723 48.6421-1 1545-0162 1545-0723 48.6421-2 1545-0162 1545-0723 48.6421-3 1545-0162 1545-0723 48.6421-4 1545-0162 1545-0723 48.6421-5 1545-0162 1545-0723 48.6421-6 1545-0162 1545-0723 48.6421-7 1545-0162 1545-0723 48.6424-0 1545-0723 48.6424-1 1545-0723 48.6424-2 1545-0723 48.6424-3 1545-0723 48.6424-4 1545-0723 48.6424-5 1545-0723 48.6424-6 1545-0723 48.6427-0 1545-0723 48.6427-1 1545-0023 1545-0162 1545-0723 48.6427-2 1545-0162 1545-0723 48.6427-3 1545-0723 48.6427-4 1545-0723 48.6427-5 1545-0723 48.6427-8 1545-1418 48.6427-9 1545-1418 48.6427-10 1545-1418 48.6427-11 1545-1418 49.4251-1 1545-1075 49.4251-2 1545-1075 49.4251-4(d)(2) 1545-1628 49.4253-3 1545-0023 49.4253-4 1545-0023 49.4264(b)-1 1545-0023 1545-0224 1545-0225 1545-0226 1545-0230 1545-0257 1545-0912 49.4271-1(d) 1545-0685 49.5000B-1 1545-2177 51.2(f)(2)(ii) 1545-2209 51.7 1545-2209 52.4682-1(b)(2)(iii) 1545-1153 52.4682-2(b) 1545-1153 1545-1361 52.4682-2(d) 1545-1153 1545-1361 52.4682-3(c)(2) 1545-1153 52.4682-3(g) 1545-1153 52.4682-4(f) 1545-0257 1545-1153 52.4682-5(d) 1545-1361 52.4682-5(f) 1545-1361 53.4940-1 1545-0052 1545-0196 53.4942(a)-1 1545-0052 53.4942(a)-2 1545-0052 53.4942(a)-3 1545-0052 53.4942(b)-3 1545-0052 53.4945-1 1545-0052 53.4945-4 1545-0052 53.4945-5 1545-0052 53.4945-6 1545-0052 53.4947-1 1545-0196 53.4947-2 1545-0196 53.4948-1 1545-0052 53.4958-6 1545-1623 53.4961-2 1545-0024 53.4963-1 1545-0024 53.6001-1 1545-0052 53.6011-1 1545-0049 1545-0052 1545-0092 1545-0196 53.6060-1(a)(1) 1545-1231 53.6065-1 1545-0052 53.6071-1 1545-0049 53.6081-1 1545-0066 1545-0148 53.6107-1 1545-1231 53.6161-1 1545-0575 54.4975-7 1545-0575 54.4977-1T 1545-0771 54.4980B-6 1545-1581 54.4980B-7 1545-1581 54.4980B-8 1545-1581 54.4980F-1 1545-1780 54.6011-1 1545-0575 54.6011-1T 1545-0575 54.6060-1(a)(1) 1545-1231 54.6107-1 1545-1231 54.9801-3 1545-1537 54.9801-4 1545-1537 54.9801-5 1545-1537 54.9801-6 1545-1537 54.9812-1T 1545-2165 54.9815-1251T 1545-2178 54.9815-2711T 1545-2179 54.9815-2712T 1545-2180 54.9815-2714T 1545-2172 54.9815-2715 1545-2229 54.9815-2719AT 1545-2181 54.9815-2719T 1545-2182 55.6001-1 1545-0123 55.6011-1 1545-0123 1545-0999 1545-1016 55.6060-1(a)(1) 1545-1231 55.6061-1 1545-0999 55.6071-1 1545-0999 55.6107-1 1545-1231 56.4911-6 1545-0052 56.4911-7 1545-0052 56.4911-9 1545-0052 56.4911-10 1545-0052 56.6001-1 1545-1049 56.6011-1 1545-1049 56.6060-1(a)(1) 1545-1231 56.6081-1 1545-1049 56.6107-1 1545-1231 56.6161-1 1545-0257 1545-1049 57.2(e)(2)(i) 1545-2249 145.4051-1 1545-0745 145.4052-1 1545-0120
  • 1545-0745
  • 1545-1076
    •      145.4061-1 1545-0224 1545-0230 1545-0257 1545-0745 156.6001-1 1545-1049 156.6011-1 1545-1049 156.6060-1(a)(1) 1545-1231 156.6081-1 1545-1049 156.6107-1 1545-1231 156.6161-1 1545-1049 157.6001-1 1545-1824 157.6011-1 1545-1824 157.6060-1(a)(1) 1545-1231 157.6081-1 1545-1824 157.6107-1 1545-1231 157.6161-1 1545-1824 301.6011-2 1545-0225 1545-0350 1545-0387 1545-0441 1545-0957 301.6011(g)-1 1545-2079 301.6017-1 1545-0090 301.6034-1 1545-0092 301.6036-1 1545-0013 1545-0773 301.6047-1 1545-0367 1545-0957 301.6056-1 1545-2251 301.6056-2 1545-2251 301.6057-1 1545-0710 301.6057-2 1545-0710 301.6058-1 1545-0710 301.6059-1 1545-0710 301.6103(c)-1 1545-1816 301.6103(n)-1 1545-1841 301.6103(p)(2)(B)-1 1545-1757 301.6104(a)-1 1545-0495 301.6104(a)-5 1545-0056 301.6104(a)-6 1545-0056 301.6104(b)-1 1545-0094 1545-0742 301.6104(d)-1 1545-1655 301.6104(d)-2 1545-1655 301.6104(d)-3 1545-1655 301.6109-1 1545-0003 1545-0295 1545-0367 1545-0387 1545-0957 1545-1461 1545-2242 301.6109-3 1545-1564 301.6110-3 1545-0074 301.6110-5 1545-0074 301.6111-1T 1545-0865 1545-0881 301.6111-2 1545-0865 1545-1687 301.6112-1 1545-0865 1545-1686 301.6112-1T 1545-0865 1545-1686 301.6114-1 1545-1126 1545-1484 301.6222(a)-2 1545-0790 301.6222(b)-1 1545-0790 301.6222(b)-2 1545-0790 301.6222(b)-3 1545-0790 301.6223(b)-1 1545-0790 301.6223(c)-1 1545-0790 301.6223(e)-2 1545-0790 301.6223(g)-1 1545-0790 301.6223(h)-1 1545-0790 301.6224(b)-1 1545-0790 301.6224(c)-1 1545-0790 301.6224(c)-3 1545-0790 301.6227(c)-1 1545-0790 301.6227(d)-1 1545-0790 301.6229(b)-2 1545-0790 301.6230(b)-1 1545-0790 301.6230(e)-1 1545-0790 301.6231(a)(1)-1 1545-0790 301.6231(a)(7)-1 1545-0790 301.6231(c)-1 1545-0790 301.6231(c)-2 1545-0790 301.6316-4 1545-0074 301.6316-5 1545-0074 301.6316-6 1545-0074 301.6316-7 1545-0029 301.6324A-1 1545-0015 301.6361-1 1545-0024 1545-0074 301.6361-2 1545-0024 301.6361-3 1545-0074 301.6402-2 1545-0024 1545-0073 1545-0091 301.6402-3 1545-0055 1545-0073 1545-0091 1545-0132 1545-1484 301.6402-5 1545-0928 301.6404-1 1545-0024 301.6404-2T 1545-0024 301.6404-3 1545-0024 301.6405-1 1545-0024 301.6501(c)-1 1545-1241 1545-1637 301.6501(d)-1 1545-0074 1545-0430 301.6511(d)-1 1545-0024 1545-0582 301.6511(d)-2 1545-0024 1545-0582 301.6511(d)-3 1545-0024 1545-0582 301.6652-2 1545-0092 301.6685-1 1545-0092 301.6689-1T 1545-1056 301.6707-1T 1545-0865 1545-0881 301.6708-1T 1545-0865 301.6712-1 1545-1126 301.6903-1 1545-0013 1545-1783 301.6905-1 1545-0074 301.7001-1 1545-0123 301.7101-1 1545-1029 301.7207-1 1545-0092 301.7216-2 1545-0074 301.7216-2(o) 1545-1209 301.7425-3 1545-0854 301.7430-2(c) 1545-1356 301.7502-1 1545-1899 301.7507-8 1545-0123 301.7507-9 1545-0123 301.7513-1 1545-0429 301.7517-1 1545-0015 301.7605-1 1545-0795 301.7623-1 1545-0409 1545-1534 301.7654-1 1545-0803 301.7701-3 1545-1486 301.7701-4 1545-1465 301.7701-7 1545-1600 301.7701-16 1545-0795 301.7701(b)-1 1545-0089 301.7701(b)-2 1545-0089 301.7701(b)-3 1545-0089 301.7701(b)-4 1545-0089 301.7701(b)-5 1545-0089 301.7701(b)-6 1545-0089 301.7701(b)-7 1545-0089 1545-1126 301.7701(b)-9 1545-0089 301.7705-1 1545-2266 301.7705-2 1545-2266 301.7805-1 1545-0805 301.9000-5 1545-1850 301.9001-1 1545-0220 301.9100-2 1545-1488 301.9100-3 1545-1488 301.9100-4T 1545-0016 1545-0042 1545-0074 1545-0129 1545-0172 1545-0619 301.9100-6T 1545-0872 301.9100-7T 1545-0982 301.9100-8 1545-1112 301.9100-11T 1545-0123 301.9100-12T 1545-0026 1545-0074 1545-0172 1545-1027 301.9100-14T 1545-0046 301.9100-15T 1545-0046 301.9100-16T 1545-0152 302.1-7 1545-0024 305.7701-1 1545-0823 305.7871-1 1545-0823 420.0-1 1545-0710 Part 509 1545-0846 Part 513 1545-0834 Part 514 1545-0845 Part 521 1545-0848 601.104 1545-0233 601.105 1545-0091 601.201 1545-0019 1545-0819 601.204 1545-0152 601.401 1545-0257 601.504 1545-0150 601.601 1545-0800 601.602 1545-0295 1545-0387 1545-0957 601.702 1545-0429     [T.D. 8011, 50 FR 10222, Mar. 14, 1985] Editorial Note:

    For Federal Register citations affecting § 602.101, see the List of CFR Sections Affected, which appears in the Finding Aids section of the printed volume and at www.govinfo.gov.

    26 CFR (4-1-20 Edition) List of CFR Sections Affected List of CFR Sections Affected

    All changes in this volume of the Code of Federal Regulations (CFR) that were made by documents published in the Federal Register since January 1, 2015 are enumerated in the following list. Entries indicate the nature of the changes effected. Page numbers refer to Federal Register pages. The user should consult the entries for chapters, parts and subparts as well as sections for revisions.

    For changes to this volume of the CFR prior to this listing, consult the annual edition of the monthly List of CFR Sections Affected (LSA). The LSA is available at www.govinfo.gov . For changes to this volume of the CFR prior to 2001, see the “List of CFR Sections Affected, 1949-1963, 1964-1972, 1973-1985, and 1986-2000” published in 11 separate volumes. The “List of CFR Sections Affected 1986-2000” is available at www.govinfo.gov .

    2015-2019 (No regulations published) 2020 (No regulations published from January 1, 2020, through April 1, 2020) ○