2019 US Code
Title 26 - Internal Revenue Code
Subtitle A - Income Taxes
Chapter 1 - Normal Taxes and Surtaxes
Subchapter G - Corporations Used to Avoid Income Tax on Shareholders
Part I - Corporations Improperly Accumulating Surplus
Sec. 533 - Evidence of purpose to avoid income tax

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Citation 26 U.S.C. § 533 (2019)
Section Name ยง533. Evidence of purpose to avoid income tax
Section Text (a) Unreasonable accumulation determinative of purpose

For purposes of section 532, the fact that the earnings and profits of a corporation are permitted to accumulate beyond the reasonable needs of the business shall be determinative of the purpose to avoid the income tax with respect to shareholders, unless the corporation by the preponderance of the evidence shall prove to the contrary.

(b) Holding or investment company

The fact that any corporation is a mere holding or investment company shall be prima facie evidence of the purpose to avoid the income tax with respect to shareholders.

Source Credit

(Aug. 16, 1954, ch. 736, 68A Stat. 179.)

Publication Title United States Code, 2018 Edition, Supplement 1, Title 26 - INTERNAL REVENUE CODE
Category Bills and Statutes
Collection United States Code
SuDoc Class Number Y 1.2/5:
Contained Within Title 26 - INTERNAL REVENUE CODE
Subtitle A - Income Taxes
CHAPTER 1 - NORMAL TAXES AND SURTAXES
Subchapter G - Corporations Used to Avoid Income Tax on Shareholders
PART I - CORPORATIONS IMPROPERLY ACCUMULATING SURPLUS
Sec. 533 - Evidence of purpose to avoid income tax
Contains section 533
Date 2019
Laws In Effect As Of Date January 24, 2020
Positive Law No
Disposition standard
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