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Go to Treas. Reg. § 1.409(a)(9)-1 (not yet in the library — opens the official source)
81 documents · 0.43sAllIRCERISAPBGCJoint Board
  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. 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 To clarify and establish a standard process for disputes to be withdrawn from the Federal IDR process, the Departments are finalizing four conditions in which a dispute …
  3. Rev. Rul. 2004-4 — Employee stock ownership plans; S corporations; listed transactions. A finding of synthetic equity owned by a disqualified person in a nonallocation year of an…
    IRCRevenue RulingsFeb 9, 2004
    …the employee trust exception in § 318(a)(2)(B)(i). As indicated by the legislative history above, § 409(p) is intended to limit the tax benefits of ESOPs maintained by S corporations unless the ESOP provides broad based coverage for, and meaningful benefits to, rank-and-file employees. See H.R. Rep. No. 107-51, part 1,…
  4. T.C. Memo. 2014-14 — Ries Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJan 27, 2014
    …2001 U.S.C.C.A.N. 46, 200. There are significant tax consequences when an ESOP violates the section 409(p) requirements. For one, an excise tax equal to 50% of the total prohibited allocation is imposed. Sec. 4979A. Furthermore, the ESOP will not satisfy the requirements of section 4975(e)(7) and will cease to qualify …
  5. 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…
  6. REG-129709-03 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCProposed Rules (FR)Proposed Jan 18, 2005
    … be available free of charge at the hearing. Proposed Amendments to the Regulations Accordingly, 26 CFR part 1 is proposed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 is amended by adding an entry in numerical order to read, in part, as follows: Authority: 26 U.S.C. 7805…
  7. 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…
  8. PLR 201828007 — Qualifying Employer Real Property/Securities
    IRCPrivate Letter RulingsJul 13, 2018
    …(e)(7) says that a plan shall not be treated as an ESOP unless it meets the requirements of section 409(h), section 409(o), and, if applicable, section 409(n ), section 409(p), and section 664(g), and, if the employer has a registration-type class of securities (as defined in section 409(e)(4)), it meets the requiremen…
  9. 84 FR 13814 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm…
    IRCProposed Rules (FR)Proposed Apr 8, 2019
    sheet exposures. Back to Citation 3.   See 12 CFR 3.22(c)(1) (OCC); 12 CFR 217.22(c)(1) (Board); and 12 CFR 324.22(c)(1) (FDIC). Back to Citation 4.   See 12 CFR 3.22(c)(2) (OCC); 12 CFR 217.22(c)(2) (Board); and 12 CFR 324.22(c)(2) (FDIC). Back to Citation 5.   See 12 CFR 3.22(c)(3) through (5) (OCC); 12 CFR 217.22(c)…
  10. 90 FR 23303 — Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule
    IRCProposed Rules (FR)Proposed Jun 2, 2025
    .210(a)(2)(xi). Back to Citation 20.  26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D). 21.  The TiC final rules also clarify that nothing in 26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D) requires th…
  11. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  12. Treas. Reg. § 1.409(p)-1T(a) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    (a) (a) Organization of this section. Section 409(p) applies if a nonallocation year occurs in an employee stock ownership plan (ESOP), as defined in section 4975(e)(7), that holds shares of stock of an S corporation, as defined in section 1361, that are employer securities as defined in section 409(l). Paragraph (b) o…
  13. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  14. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005
    s an avoidance or evasion of section 409(p). A public hearing on the proposed regulations is scheduled for April 20, 2005. REG–129709–03 REG–129709–03 Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409(p), ident…
  15. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  16. T.D. 9302 — Final regulations under section 409(p) of the Code provide guidance concerning requirements for employee stock ownership plans (ESOPs) holding stock of Subchap…
    IRCTreasury DecisionsJan 29, 2007
    to section 409(p). * * * Par. 3. Section 1.409(p)-1 is added to read as follows: §1.409(p)-1 Prohibited allocation of securities in an S corporation. (a) Organization of this section and definition—(1) Organization of this section. Section 409(p) applies if a nonallocation year occurs in an ESOP that holds shares of s…
  17. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  18. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  19. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  20. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]