Search the Pension Law Library

1. 88 FR 75744 — Federal Independent Dispute Resolution Operations
   IRCProposed Rules (FR)Proposed Nov 3, 2023★ strong match
   ation 133.  Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)( 5), 29 CFR 2590.716-8(b)(2)(ii)(A)( 5), and 45 CFR 149.510(b)(2)(ii)(A)( 5). Back to Citation 134.  Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
2. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
   IRCFinal Rules (FR)Dec 11, 2024
   …suspension rules in §§ 1.987-10, 1.987-11, and 1.987-13. XIII. Comments and Changes to Proposed § 1.1502-13: Intercompany Transactions The 2023 proposed regulations would provide a new rule applicable to certain intercompany transactions (as defined in § 1.1502-13(b)(1)(i)) involving section 987 QBUs. See proposed § 1.…
3. 91 FR 33900 — Federal Independent Dispute Resolution Operations
   IRCFinal Rules (FR)Jun 4, 2026★ strong match
   mission of additional information from the disputing parties at 26 CFR 54.9816-8(c)(2)(ii), 29 CFR 2590.716-8(c)(2)(ii), and 45 CFR 149.510(c)(2)(ii). To clarify and establish a standard process for disputes to be withdrawn from the Federal IDR process, the Departments are finalizing four conditions in which a dispute …
4. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
   IRCProposed Rules (FR)Proposed Nov 14, 2023
   onstitutes an intercompany transaction (as defined in § 1.1502-13(b)(1)(i)) and is subject to the intercompany transaction regulations in § 1.1502-13. The Treasury Department and the IRS have become aware that achieving single entity treatment under § 1.1502-13 may be difficult for certain intercompany transactions inv…
5. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
   IRCProposed Rules (FR)Proposed Sep 16, 2021related by meaning
   posed amendments to 45 CFR 150.205(e)(2) would correct a typographical error which incorrectly referenced in 45 CFR 148.120 instead of 45 CFR 148.210. 6. Notice to the State (45 CFR 150.211)
6. PLR 199913003 — Amount of Deduction
   IRCPrivate Letter RulingsApr 2, 1999
   the pro rata allocation me thod of Treas. Reg. ' 1.1502 - 76(b)(4)(ii) must be utilized. See , PLR 82-30-041 (April 27, 1982); GCM 39,292, (April 30, 1984), for examples in which the Service based its Treas. Reg. ' 1.1502-76(b)(4)(ii) allocation on the rationale that information from the permanent books and records wa…
7. 86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
   IRCFinal Rules (FR)Jan 6, 2021
   2 (FDIC) (“synthetic exposure”). Back to Citation 32.   See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”). Back to Citation 33.   See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC). Back to Citat…
8. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
   IRCProposed Rules (FR)Proposed Aug 3, 2023
   15-2715A1(a)(2)(xx), 29 CFR 2590.715-2715A1(a)(2)(xix), 45 CFR 147.210(a)(2)(xx). Back to Citation 170.  29 CFR 2520.102-2(a). Back to Citation 171.   See 26 CFR 54.9815-2715(a)(4)(ii)(B), 29 CFR 2590.715-2715(a)(4)(ii)(B), 45 CFR 147.200(a)(4)(ii)(B). Back to Citation 172.  26 CFR 54.9815-2719, 29 CFR 2590.715-2719, a…
9. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
   IRCPrivate Letter RulingsOct 15, 1999
   …ars of Mutual ending on or before the Closing Date will be treated as taxable years of Company (§ 1.1502-75(d)(2)(iii)). (13) Company will close its taxable year on the Closing Date. All taxable years of Company ending on or before the Closing Date will be treated as taxable years of Mutual (§ 1.1502-75(d)(2)(iii)). (1…
10. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …filiated group on the effective date will determine their status as eligible corporations under § 1.1502-47(d)(12). See , § 1.150247(d)(12)(vi). (9) For purposes of § 1.1502-31 and § 1.1502-33, the proposed transaction will qualify as a "group structure change" (under § 1.1502-75(d)(2) and/or (3)). Mutual Holding's bas…
11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …has filed a consolidated return for a year is referred to as a consolidated group. 26 C.F.R. sec. 1.1502-1(h), (a) (2019). A consolidated group has only one income tax liability for the year. Sec. 1503(a); 26 C.F.R. sec. 1.1502-2(a) (2019). Each member of a consolidated group is severally liable for the income tax. Sec…
12. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
13. 29 C.F.R. § 2520.104a-7 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
14. 29 C.F.R. § 2520.102-1 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
15. 29 C.F.R. § 2520.104-45 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
16. 29 C.F.R. § 4281.14-4281.15 — [Reserved]
    PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
17. 29 C.F.R. § 2520.101-4 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
18. 29 C.F.R. § 4907.141-4907.148 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
19. 29 C.F.R. § 2530.207-2530.209 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
20. 29 C.F.R. § 4907.152-4907.159 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]