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.…
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…
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…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
ns
were made negligently or intentionally.”) (emphasis added);
see Mathews
v.
Chevron Corp.,
362 F.3d 1172, 1183 (9th Cir. 2004).
Back to Citation
37. 84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
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…
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…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
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…
ERISARegulationsJan 1, 2017related by meaning
(i) (i) Service of notices and filing of statements.
(i)(1) (1) Service of a notice for purposes of paragraphs (c) and (g) of this section shall be made:
(i)(1)(i) (i) By delivering a copy to the administrator or representative thereof;
(i)(1)(ii) (ii) By leaving a copy at the principal office, place of business, or re…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024★ strong match
ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
75 FR 8796 — Civil Penalties Under ERISA Section 502(c)(8) ERISAFinal Rules (FR)Feb 26, 2010related by meaning
oard, or other official; and
(q)
Solicitor
means the Solicitor of Labor or his or her delegate.
§ 2570.162
Service: Copies of documents and pleadings. For 502(c)(8) penalty proceedings, this section shall apply in lieu of § 18.3 of this title.
( printed page 8802)
(a)
General.
Copies of all documents shall be served on…
81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
regulations at 31 CFR Chapter X.
See 31 CFR 1010.100(e).
Back to Citation
2.
31 U.S.C. 5311.
Back to Citation
3.
31 U.S.C. 5318.
Back to Citation
4. Treasury Order 180-01 (Jul. 1, 2014).
Back to Citation
5.
31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section …
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.3 of this title.