84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
izations.
Estimated average hours per response:
Sections 249.40(a), 249.110(a), 249.206(a), 249.207(a) (3 respondents)
Reporting (ongoing monthly)—.50 Sections 249.40(b), 249.110(b), 249.206(b), 249.207(a) (3 respondents)
Reporting (ongoing)—.50
Sections 249.40(b)(3)(iv), 249.110(b)(3), 249.206(b)(iv),249. 207(b)(3) (3…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…ution holding company, U.S. intermediate holding company, or covered nonbank company described in § 249.104(d)(6) (row 10); (xi) The average weighted amount and, for each applicable maturity category, the average unweighted amount of other wholesale funding described in §§ 249.104(a)(2), 249.104(d)(1), 249.104(d)(2), 2…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
…nd loan holding companies, and foreign banking organizations.
Estimated average hours per response:
249.40(a) (3 respondents)
Reporting (ongoing monthly)—.50
249.40(b) (3 respondents)
Reporting (ongoing)—.50
249.40(b)(3)(iv) (3 respondents)
Reporting (quarterly)—.50
249.22(a)(2) & (a)(5) (23 respondents)
Recordkeeping …
IRCCourt RulingsJul 14, 2005related by meaning
0 31
useaee
CAL,
Js.r. Juoca
T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…egulated institution that is not a secured lending transaction or a security.
* * * * *
16. Amend § 249.22, by revising paragraph (b)(1) to read as follows:
§ 249.22
Requirements for eligible high-quality liquid assets.
* * * * *
(b) * * *
(1) The assets are not encumbered.
* * * * *
17. Amend § 249.30, by revising par…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
is section.
23. In § 249.90, paragraph (b)(3) is revised to read as follows:
§ 249.90
Timing, method and retention of disclosures.
* * * * *
(b) * * * (3) A covered depository institution holding company or covered nonbank company that is subject to the minimum liquidity standard and other requirements of this part pur…
79 FR 61440 — Liquidity Coverage Ratio: Liquidity Risk Measurement Standards IRCFinal Rules (FR)Oct 10, 2014
. In § 249.40, revise paragraph (b)(1) to read as follows:
§ 249.40
Liquidity coverage shortfall: Supervisory framework.
* * * * *
(b)
Liquidity plan. (1) For the period during which a Board-regulated institution must calculate a liquidity coverage ratio on the last business day of each applicable calendar month under …
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…