IRCPrivate Letter RulingsNov 6, 2020
4980(d)(2)(C)(i)(II) (after application of § 4980(d)(2)(C)(ii)).
Section 4980(d)(2)(C)(iv) provides that if any amount credited to a suspense account under § 4980(d)(2)(C)(i)(II) is not allocated as of the termination date of the replacement
plan, (I) such amount shall be allocated to the accounts of the participants …
PLR 202506005 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsFeb 7, 2025
(2)(C)(iii) provides that any income on any amount credited to a
suspense account under section 4980(d)(2)(C)(i)(II) shall be allocated to accounts of participants no less rapidly than ratably over the remainder of the period determined
under section 4980(d)(2)(C)(i)(II) (after application of section 4980(d)(2)(C)(ii))…
PLR 202550025 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsDec 12, 2025
…n of such limitation, it sh all be allocated to
the participant as provided in section 415. Section 4980(d)(2)(C)(iii) provides that any income on any amount credited to a
suspense account under section 4980(d)(2)(C)(i)(II) shall be allocated to accounts of
participants no less rapidly than ratably over the remainder o…
79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage IRCFinal Rules (FR)Feb 12, 2014related by meaning
…* * *
(8) * * *
(i) * * *
(E) Assessment and collection of an assessable payment imposed by section 4980H and reporting required by section 6056.
* * * * *
PART 54—PENSION EXCISE TAXES
Par. 3.
The authority citation for part 54 is amended by adding entries in numerical order to read as follows:
Authority:
26 U.S.C. 780…
PLR 202631008 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJul 31, 2026
(2)(C)(iii) provides that any income on any amount credited to a
suspense account under section 4980(d)(2)(C)(i)(II) shall be allocated to accounts of participants no less rapidly than ratably over the remainder of the period determined
unde r section 4980(d)(2)(C)(i)(II) (after application of section 4980(d)(2)(C)(ii)…
PLR 202348005 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsDec 1, 2023
)(iv) provides that if any amount credited to a suspense account
under section 4980(d)(2)(C)(i)(II) is not allocated as of the termination date of the replacement plan, (I) such amount shall be allocated to the accounts of the participants
as of such date, except that any amount which may not be allocated by reason of …
PLR 202435008 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsAug 30, 2024
…the transfer of surplus assets to the suspense account should be treated in
accordance with section 4980(d)(2)(B)(iii).
3. That the amounts allocated from the suspense account to participants’ accounts
for each year from Year 1 through Year 6 met the requirements of the Code.
4. That the $H remaining in the suspense ac…
IRCPrivate Letter RulingsJun 24, 2016
e 7-plan-year period beginning with the year of the
transfer.
Under section 4980(d)(2)(C)(ii) , if by reason of any limitation under section 415 , any amount credited to a suspense account under section 4980(d)(2)(C)(i)(II) may not be
allocated to a participant before the close of the 7-plan-year period, such amount sh…
PLR 202230006 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJul 29, 2022
of the allocation period under the same
procedure.
Applicable Law
Section 4980(a) provides for a 20 percent excise tax on the amount of any reversion from a qualified plan.
PLR - 123575-21 5
Section 4980(c)(2) generally defines the term “employer reversion” as the amount of
cash and the fair market value of other prop…
PLR 202429010 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJul 19, 2024
…e as
soon as a dministratively feasible following the termination of Plan A.
Applicable Law
Section 4980(a) provides for a 20 percent excise tax on the amount of any reversion
from a qualified plan.
Sectio n 4980(c)(2) generally defines the term “employer reversion” as the amount of
cash and the fair marke t value of o…
78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage IRCProposed Rules (FR)Proposed Jan 2, 2013related by meaning
…* * *
(8) * * *
(i) * * *
(E) Assessment and collection of an assessable payment imposed by section 4980H and reporting required by section 6056.
* * * * *
PART 54—PENSION EXCISE TAXES
Par. 3.
The authority citation for part 54 is amended by adding entries in numerical order to read as follows:
Authority:
26 U.S.C. 780…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCPrivate Letter RulingsMar 19, 2021
…ovides for certain benefit increases which take effect
immediately on the termination date.
Section 4980(c)(2) generally defines the term "employer reversion" as the amount of
cash an d the fair market value of other property received (directly or indirectly) by an
employer from the qualified plan.
Section 4980(d)(2) p…
PLR 200226001 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJun 28, 2002
…enue. In re Juvenile Shoe Corporation of America
, 99 F.3d at 903. It also noted that, unlike IRC § 4980, the conduct taxed by IRC §
4971 is prohibited under federal law, citing to the minimum funding requirements
applicable to pension plans. See
29 U.S.C. § 1001 (1988). Accordingly, the court
concluded that the primar…
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, 2024related by meaning
…rs Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discharge that include as grounds for th…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023related by meaning
U.S.C. 1108), 112 Stat. 2061; 25 U.S.C. 1647b.
2. Section 890.114 is amended by revising paragraph (a) to read as follows:
§ 890.114
Surprise billing. (a) A carrier must comply with requirements described in 26 CFR 54.9816-3, 54.9816-3T through 54.9816-6T, 54.9816-6A, 54.9816-6, 54.9816-8T, 54.9816-8, 54.9817-1T, 54.98…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
IRCPrivate Letter RulingsMar 19, 2021
allocation r equirements
of §§ 4980(d)(2)(A), (B), and (C).
Section 4980(d)(2)(A) requires that at least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination be
active participants in the replacement plan.
Section 4980(d)(2)(B) requires that a direc…
IRCCode / StatuteJan 6, 2025related by meaning
(d)(13) (13) any transaction which is exempt from section 406 of such Act by reason of section 408(e) of such Act (or which would be so exempt if such section 406 applied to such transaction) or which is exempt from section 406 of such Act by reason of section 408(b)(12) of such Act;
(d)(14) (14) any transaction requir…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…