[Code of Federal Regulations]
[Title 26, Volume 7]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.547-7]

[Page 283]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.547-7  Effective date.

    The deduction for deficiency dividends, in computing personal 
holding company tax for any taxable year, is allowable only with respect 
to determinations under section 547(c) made after November 14, 1954 (the 
date falling 90 days after the date of enactment of the Internal Revenue 
Code of 1954). If the taxable year with respect to which the deficiency 
is asserted began before January 1, 1954, the deficiency dividends 
deduction shall include only the amounts which would have been 
includible in the computation of the basic surtax credit for such 
taxable year under the Internal Revenue Code of 1939. Section 547(g), 
relating to the denial of a deficiency dividends deduction if the 
determination contains a finding that any part of the deficiency is due 
to fraud, etc., shall apply only if the taxable year with respect to 
which the deficiency is asserted begins after December 31, 1953.

                   Foreign Personal Holding Companies