Section 860 allows a qualified investment entity to be relieved from the payment of a deficiency in ( or to be allowed a credit or refund of ) certain taxes . “ Qualified investment entity ” is defined in section 860 ( b ) .
A qualified investment entity is allowed a deduction for a deficiency dividend only if there is a determination ( as defined in section 860 ( e ) and paragraph ( b ) ( 1 ) of this section ) that results in an adjustment ( as defined in ...
If a qualified investment entity is allowed a deduction for deficiency dividends with respect to a taxable year , under section 860 ( c ) ( 1 ) the tax imposed on the entity by chapter 1 of the Code ( computed by taking into account the ...
( 3 ) Qualified entity defined . ( d ) Election to be treated as a real estate mortgage investment conduit . ... ( b ) Tax on pass - thru entities . ( 1 ) Tax on excess inclusions . ( 2 ) Record holder furnishes information under ...
Section 1.860E2 ( b ) ( 1 ) is effective for excess inclusions accruing to pass - thru entities after March 31 , 1988 . ... by a qualified entity ( as defined in $ 1.860D - 1 ( c ) ( 3 ) ) whose startup date ( as defined in section 860G ...