§526 — Shipowners’ protection and indemnity associations
27 cases·1 followed·2 overruled·24 cited—4% support
Statute Text — 26 U.S.C. §526
There shall not be included in gross income the receipts of shipowners’ mutual protection and indemnity associations not organized for profit, and no part of the net earnings of which inures to the benefit of any private shareholder; but such corporations shall be subject as other persons to the tax on their taxable income from interest, dividends, and rents.
27 Citing Cases
Section 45C(b)(2)(B) provides that the Orphan Drug Credit may be allowed for qualified clinical testing expenses related to a "rare disease or condition * * * designated under section 526 ofthe Federal Food, Drug, and Cosmetic Act." Section 41(c) explains that the Increasing Research Activities Credit may be allowed for research and
1944) (in view of section 1111(b), a trust was considered a transferee although section 526(f) of the Internal Revenue Code of 1932, ch.
1944) (in view of section 1111(b), a trust was considered a transferee although section 526(f) of the Internal Revenue Code of 1932, ch.
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
mployees as employees of the recipient of their services for purposes of the qualified plan requirements. H. Conf. Rept. 97-760, at 79 (1982), 1982-2 C.B. 600, 679. In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 526(d)(1), 98 Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986,
or such [gift] tax to the extent of the value of such gift." It contains no provision authorizing a reduction on account of any lien resulting from the gift. The obvious intent of the legislation, especially the transferee provisions of the statute (Sec. 526 Revenue Act of 1932), is to protect the revenue by providing, in effect, that one who receives property by gift may, if necessary, be required to pay all of it (but no more) over to the fiscus. If the construction urged upon us by the petiti
or such [gift] tax to the extent of the value of such gift.” It contains no provision authorizing a reduction on account of any lien resulting from the gift. The obvious intent of the legislation, especially the transferee provisions of the statute (Sec. 526 Revenue Act of 1932), is to protect the revenue by providing, in effect, that one who receives property by gift may, if necessary, be required to pay all of it (but no more) over to the fiscus. If the construction urged upon us by the petiti