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Go to I.R.C. § 351 (not yet in the library — opens the official source)
76 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  2. 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…
  3. 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
    hich is owned by U.S. Corp, in a transaction qualifying under section 351. U.S. Corp and DS are members of the same consolidated group. (ii) Analysis. Pursuant to § 1.987-2(c)(2)(i) and (ii), as a result of the deemed exchange of the assets and liabilities of Business A for DS stock in a section 351 transaction, Busine…
  4. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  5. 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
    a personal residence, if the facts are not similar to those described in Rev. Rul. 83-51, 1983-1 C.B. 48. (Also §§ 61, 451, 461, 856, 1001, and 7701.) (37) Sections 165, 381, and 1502.—Losses; Carryovers in Certain Corporate Acquisitions; Regulations.—In determining whether a loss for worthless securities is subject to…
  6. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …& Dana P. Goldman, Overpaying for Prescription Drugs: The Copay Clawback, (2018), https://schaeffer.usc.edu/​research/​overpaying-for-prescription-drugs/​.) Back to Citation 183.  Megan Thompson (2018), W hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/​newshour/​health/​why-a-patient-paid-a-285-copa…
  7. 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…
  8. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ies. Subchapter C, consisting solely of section 6751, sets forth “Procedural Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
  9. Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions
    IRCNoticesAug 24, 2026
    …rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
  10. 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…
  11. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
  12. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    Pensions Railroad retirement Reporting and recordkeeping requirements Social security Unemployment compensation Proposed Amendments to the Regulations Accordingly, 26 CFR part 31 is proposed to be amended as follows: PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME AT THE SOURCE Paragraph 1. The authority citation for…
  13. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …S-Corp. stock, as was necessary to qualify for nonrecognition of income under - 19 - [*19] sections 351(a) and 368(c). Respondent urges that petitioners are improperly "trying to have it both ways." We are unpersuaded by this argument. Respondent does not contend that the section 351 exchange was invalid and has not so…
  14. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  15. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    atement for any taxable year, there shall be added to the tax an amount equal to 20% of the amount of such understatement." The penalty applies to any deficiency which is attributable to any listed transaction or any reportable transaction if a significant purpose of the transaction is the avoidance or evasion - 41 - o…
  16. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960related by meaning
    x under this section shall be in lieu of the 25 per centum addition to the tax provided ip section 3512(d).(1). SEC. 6651. EAILURE TO FILE TAX RETURN. (b) Penalty Imposed on Net Amount Due. — For purposes of subsection (a), the amount of tar required to be shown on the return shall be reduced by the amount of any part …
  17. Treas. Reg. § 54.9825-3T — Definitions (temporary).
    IRCRegulationsDec 23, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  18. 78 FR 53704 — Employee Retirement Benefit Plan Returns Required on Magnetic Media
    IRCProposed Rules (FR)Proposed Aug 30, 2013related by meaning
    ublic hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the Federal Register . Drafting Information The principal authors of these regulations are William Gibbs and Pamela R. Kinard, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities…
  19. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …3.01(22) of Rev. Proc. 98-3, 1998-1 I.R.B. 102-3, the Service will not rule on the application of § 351 of the Code to an exchange of stock in the formation of a holding company. However, the Service has the discretion to rule on significant subissues that must be resolved to determine whether the transaction qualifies…
  20. 76 FR 69126 — Graduated Retained Interests
    IRCFinal Rules (FR)Nov 8, 2011related by meaning
    sthroughs and Special Industries), IRS. List of Subjects in 26 CFR Part 20 Estate taxes Reporting and recordkeeping requirements ( printed page 69128) Adoption of Amendments to the Regulations Accordingly, 26 CFR part 20 is amended as follows: PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Paragra…