Swallows Holding, Ltd. - Page 60

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          Thus, before the enactment of the 1954 Code, a foreign                      
          corporation such as petitioner was required to file its Federal             
          income tax returns at Baltimore, Maryland.                                  
               Since the enactment of the 1954 Code, a corporation                    
          generally must file its Federal income tax returns with the                 
          District Director for the internal revenue district in which is             
          located the corporation’s principal place of business, principal            
          office, or agency.  See sec. 6091(b)(2)(A); see also sec.                   
          1.6091-2(b), Income Tax Regs.  The rule is different where a                
          foreign corporation has no principal place of business, principal           
          office, or agency in any internal revenue district.  See sec.               
          6091(b)(2)(B)(i), (iii).  In that case, section 6091(b)(2)(B)(i)            
          and (iii) allows the Secretary to designate by regulation the               
          place where the foreign corporation’s return will be filed.                 
               As relevant here, section 1.6091-3(f), Income Tax Regs.                
          (before amendment on September 15, 2004, by T.D. 9156, 2004-2               
          C.B. 669, 671), generally required that a foreign corporation               
          file its Federal income tax returns with the “Director of                   
          International Operations, Internal Revenue Service, Washington,             
          D.C. 20225, or the district director, or the director of the                
          service center, depending on the appropriate officer designated             
          on the return form or in the instructions issued with respect to            
          such form”.  That section was issued by the Secretary in 1959.              
          See T.D. 6364, 1959-1 C.B. 546, 604.  In the 1972 instructions              





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