88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
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).
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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…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
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 To clarify and establish a standard process for disputes to be withdrawn from the Federal IDR process, the Departments are finalizing four conditions in which a dispute …
IRCPrivate Letter RulingsFeb 7, 2025
the right at the
time of the transfer, whichever is greater.
Section 1.691(a) - 4(b) provides that if the estate of a decedent or any person transmits the right to IRD to another who would be required by § 691(a)(1) to include such income
PLR - 109140-24
5
when received in his gross income, only the transferee will inc…
IRCPrivate Letter RulingsMar 1, 2019
…or the fair market value of the right at the
time of the transfer, whichever is g reater. Section 1.691(a) - 4(b) provides that if the estate of a decedent or any person transmits
the right to IRD to another who would be required by section 691(a)(1) to include such
income when received in his gross income, only the tr…
IRCPrivate Letter RulingsJan 30, 2009
…tallment obligation at other than face value, which is likewise
considered a transfer under section 691(a)(2), see section 1 .691(a) - 5.
Section 1.691(a) - 4(b) provides that if the estate of a decedent or any person transmits
the right to income in respect of a decedent to another who would be required by
section 691…
IRCPrivate Letter RulingsAug 21, 2020
… or for a previous taxable year under the method of accounting employed by the dece dent. Section 1.691(a) - 1(c) provides
that the term “income in respect of decedent” also includes the amount of all items of
gross income in respect of a prior decedent, if (1) the right to receive such amount was
acquired by the deced…
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”).
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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”).
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33.
See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC).
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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).
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170.
29 CFR 2520.102-2(a).
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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).
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172.
26 CFR 54.9815-2719, 29 CFR 2590.715-2719, a…
IRCCourt RulingsMay 14, 2012
…Docket No. 3143-10. Filed May 14, 2012.
R determined that for 2007 P failed to report income of
$11,691 from the Los Angeles County Employees Retirement
Association received on account of a divorce agreement, treated like a
qualified domestic relations order, awarding her a portion of her
former husband's disability pa…
125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner IRCCourt RulingsNov 17, 2005
… against the beneficiaries of the accounts when the
accounts are distributed. See secs. 408(d) (1), 691(a) (1) (B). To
compensate (at least partially) for this potential double
taxation, Congress enacted section 691(c), which grants the
recipient of an item of IRD an income tax deduction equal to the
amount of Federal …
IRCRegulationsJan 19, 2017
…te of the individual to whom the option was granted. Such deduction shall be computed under section 691(c) by treating the option as an item of gross income in respect of a decedent under section 691 and by treating the amount required to be included in gross income under section 423(c) as an amount included in gross i…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
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).
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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…
IRCPrivate Letter RulingsJul 25, 2014
…me for the taxable year ending with the date of
his death or for a previous taxable year. Section 1.691 (a)-4(a) of the Regulations provides that in general, the transferor must
include
in his gross income for the taxable period in which the transfer occurs the
amount
of the consideration, if any, received for the righ…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]