83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…0(a)(1) and (a)(1)(iv)).
2. Exemption for Objecting Entities Based on Moral Convictions (45 CFR 147.133(a))
3. Exemption for Certain Plan Sponsors (45 CFR 147.133(a)(1)(i))
a. Plan sponsors in general (45 CFR 147.133(a)(1)(i) prefatory text)
b. Nonprofit organizations (45 CFR 147.133(a)(1)(i)(A))
c. For-Profit Entities…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsSep 13, 2017
…r section 72 (relating to annuities)." It
is undisputed that petitioner received a distribution of $133,501 in 2012 from the
- 8 -
[*8] Vanguard-administered plan, a qualified retirement plan. Accordingly, the
entire distribution is taxable to petitioners unless some exclusion applies.
Petitioners contend that $25,000 …
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…he reference “147.131 and 147.132” and adding in its place the reference “147.131, 147.132, and 147.133”.
§ 54.9815-2713AT
[Amended]
3. Section 54.9815-2713AT, as added elsewhere in this issue of the Federal Register
], is amended—
a. In paragraph (a)(1) by removing “or (ii)” and adding in its place “or (ii), or 45 CFR…
IRCRegulationsMay 18, 2016
The following questions and answers concern the written explanation requirement imposed by section 402(f) of the Internal Revenue Code of 1986 relating to distributions eligible for rollover treatment. Section 402(f) was amended by section 521(a) of the Unemployment Compensation Amendments of 1992, Public Law 102-318, …
79 FR 56442 — Additional Rules Regarding Hybrid Retirement Plans IRCFinal Rules (FR)Sep 19, 2014
… plan years.
One commenter on the 2010 proposed regulations suggested that a special rule under the 133
1/3 percent rule of section 411(b)(1)(B) should not be provided for variable interest crediting rates that can potentially be negative. Other commenters suggested that the interest crediting rate to be used for purpo…
IRCFinal Rules (FR)Jul 19, 2024
-2”.
§ 1.401(a)(31)-1, Q&A-14(b)(1)
“§ 1.402-2(c)-2, Q&A-1”
“§ 1.402(c)-2(a)”.
§ 1.401(a)(31)-1, Q&A-14(b)(1)
“§ 1.402(c)-2, Q&A-9”
“§ 1.402(c)-2(g)”. § 1.401(a)(31)-1, Q&A-14(b)(2)
“§ 1.402(c)-2, Q&A-1”
“§ 1.402(c)-2(a)”.
§ 1.401(a)(31)-1, Q&A-16
“§ 1.402(c)-2(b), Q&A-9”
“§ 1.402(c)-2(g)”.
§ 1.401(a)(31)-1, Q&A-17
“§ …
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsMay 19, 2011★ strong match
…of a distribution from a nonexempt employee
trust, a situation specifically contemplated by section 402(b). Section 83, which addresses the taxation of property transferred
in connection with services, is thus general when compared with
the specific application of section 402(b) to a distribution from
a nonexempt emplo…
IRCCourt RulingsJan 26, 1984★ strong match
… after the trust had lost its exempt status. We held that this amount should be taxed under section 402(b) as ordinary income in 1974 but that the remaining $22,842.59 should be taxed under section 402(a) as a distribution from a qualified plan resulting in long-term capital gain. We held that "the assets in a distribu…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
contractor or subcontractor” within the meaning of section 403 (a) (4) (D), as to all contracts whether executed by itself or by the Georgia company. The respondent contends that the separate entities may not be ignored. He states that under the Mississippi company’s method of operation, that is, at cost, that company…
IRCCourt RulingsMay 30, 1984related by meaning
was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
T.D. 9937 — This document sets forth final regulations relating to amendments made to section 402(c) of the Internal Revenue Code (Code) by section 13613 of the Tax Cuts a… IRCTreasury DecisionsJan 25, 2021
…th respect to Division O of the Further Consolidated Appropriations Act of 2020, Public Law 116-94 (133 Stat. 2534), titled “Setting Every Community Up for Retirement Enhancement Act of 2019” (SECURE Act). As part of that guidance, the Treasury Department and IRS anticipate amending §1.402(c)-2 to reflect changes made …
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017
…a. In paragraph (a)(1) by removing the language “(ii)” and adding in its place “(ii), or 45 CFR 147.133(a)(1)(i) or (ii)”. b. In paragraph (a)(2) by adding the language “or 147.133(a)” after “147.132(a)”.
c. In paragraph (b)(1)(ii) introductory text by removing the language “147.132” and adding in its place “147.132(ii…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsApr 22, 1992related by meaning
Finally, petitioners argue that a literal reading of section 402(e)(4)(B) leads to absurd results. In support of their argument, petitioners provide several examples of the disparate treatment among taxpayers that emanates from a literal application of section 402(e)(4)(B). Granted that a literal reading may, under cer…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…by the amount of the AIR ($500,000 − $300,000). The reduced deduction limit is then applied to O’s $133,333 of DDR attributable to services performed by O in L’s 2017 taxable year that is paid in 2018. Because $133,333 does not exceed that reduced deduction limit of $200,000, the $133,333 is deductible for 2018. The de…
86 FR 464 — Rollover Rules for Qualified Plan Loan Offset Amounts IRCFinal Rules (FR)Jan 6, 2021
…th respect to Division O of the Further Consolidated Appropriations Act of 2020, Public Law 116-94 (133 Stat. 2534), titled “Setting Every Community Up for Retirement Enhancement Act of 2019” (SECURE Act). As part of that guidance, the Treasury Department and IRS anticipate amending § 1.402(c)-2 to reflect changes made…