ERISACourt RulingsSep 17, 2026
…liability’ is defined by the statute as ‘the amount determined’ by the four -step process in section 1381.”).
Additionally, the Fund points to § 1381(a)’s language that
“the employer is liable to the plan in the amount determined
under this part [.]” 29 U.S.C. § 1381(a) (emphas i s added). In its
view, Consumers’s appro…
IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsNov 30, 2006★ strong match
…ce the
laws as written and interpreted, see Marsh & McLennan Cos. v.
United States
, 302 F.3d 1369, 1381 (Fed. Cir. 2002); Philadelphia
& Reading Corp. v. United States
, 944 F.2d 1063, 1074 (3d Cir.
1991). The result in this case is harsh, and unfortunately the
Court can appreciate why petitioners will regard it as su…
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…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
nder section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
ADMINISTRATIVE
Rev. Proc. 2006-34 Rev. Proc. 2006-34 This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure …
IRCCode / StatuteJan 24, 2020
…oses of this paragraph or as a corporation operating on a cooperative basis for purposes of section 1381(a)(2)(C) by reason of the treatment under clause (i).
(c)(12)(H)(ix) (ix) For purposes of subparagraph (A), in the case of a mutual or cooperative electric company, income received, or accrued, indirectly from a mem…
IRCPrivate Letter RulingsSep 14, 2007related by meaning
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REG-113792-13 — These proposed regulations provide guidance on the tax credit available to certain small employers that offer health insurance coverage to their employees unde… IRCProposed Rules (FR)Proposed Sep 16, 2013
…However, a farmers’ cooperative described in section 521 that is subject to tax pursuant to section 1381 and otherwise meets the requirements of this section is an eligible small employer.
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
ERISACode / StatuteJan 24, 2020
…(or is delinquent with respect to paying) the full amount of its withdrawal liability under section 1381(b)(1) of this title or an agreement with the plan,
(e)(9)(D)(vii)(II) (II) second, except as provided by subclause (III), be applied to all other benefits that may be suspended under this paragraph, and
(e)(9)(D)(vi…
ERISACode / StatuteJan 6, 2025
…ficiary who is determined, under title II or XVI of the Social Security Act [42 U.S.C. 401 et seq., 1381 et seq.], to have been disabled at any time during the first 60 days of continuation coverage under this part, any reference in clause (i) or (ii) to 18 months is deemed a reference to 29 months (with respect to all…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCRegulationsDec 30, 2016
…ate of a final determination under title II or XVI of the Social Security Act (42 U.S.C. 401-433 or 1381-1385) that the disabled qualified beneficiary whose disability resulted in the qualified beneficiary's being entitled to the disability extension is no longer disabled, whichever is earlier; or
(6)(ii) (ii) The end …
T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec… IRCTreasury DecisionsAug 12, 2024related by meaning
isted transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
T.D. 10004, page 489. This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizat…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsFeb 28, 2024related by meaning
8
years on June 10, 2016. That notice was issued timely because, as of
3
The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
IRCCourt RulingsFeb 25, 2014
…rce the laws as written and interpreted. See Marsh &
McLennan Cos. v. United States, 302 F.3d 1369, 1381 (Fed. Cir. 2002); Phila. &
Reading Corp. v. United States, 944 F.2d 1063, 1074 (3d Cir. 1991). The Court
may not "'revise the language of the statute as interpreted by the Treasury to
achieve what might be perceived…
Notice 2024-16 — Guidance Related to Section 961 and Certain Inbound Nonrecognition Transactions IRCNoticesJan 29, 2024related by meaning
3 of this notice should apply to transactions other than covered inbound transactions and whether additional limitations should apply in those cases. Comments should be submitted by February 26, 2024. Comments may be submitted electronically via the Federal eRulemaking Portal at www.regulations.gov (type IRS-2024-16 i…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
PBGCCode / StatuteJan 5, 2015
…ars following the date of the partition order, withdrawal liability shall be computed under section 1381 of this title with respect to both the plan that was partitioned and the plan created by the partition order. If the withdrawal occurs more than ten years after the date of the partition order, withdrawal liability …