80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
es may engage in covered transactions subject to the recapture of profits limitations in Section V(b) of the exemption.
VI. Recordkeeping Requirements A proposed new Section VI to PTE 86-128 would require the fiduciary engaging in a transaction covered by the exemption to maintain records necessary to enable certain pe…
IRCCourt RulingsOct 25, 1999
T.C. Memo. 1999-352
UNITED STATES TAX COURT
LUISA DEAL, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12757-98. Filed October 25, 1999.
Luisa Deal, pro se.
Yvonne M. Peters
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: Respondent determined a
deficien…
PBGCRegulationsJan 1, 2017
e year of the proposed termination date, is $2,352.27 per month, payable in the form of a single life annuity at age 65. Because the participant is older than age 65, no adjustment is required under § 4022.23(c) based on the annuitant's age factor. The benefit form is a joint and survivor annuity (contingent basis), as…
IRCCourt RulingsNov 17, 2016
…35
2003 160,000 69,687 53,150
2004 165,000 71,633 54,811
2005 170,000 74,170 56,472
2006 175,000 76,352 58,133
In view of his computation pursuant to section 415(b)(2)(C) of lower reduced
benefit limits, respondent in the notice of deficiency further calculated allowable
deduction limits. Since respondent computed lowe…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
ion under PTE 77-4. The Department requests comment on this proposed revocation, and also on how the remaining parts of PTE 75-1 Part II will be used. The Department is further proposing to revise the recordkeeping provisions of Section (e) of PTE 75-1, Part II. Section (e) currently provides that records demonstrating…
80 FR 22010 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and B… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
ection IV(c) may be presumed if the independent plan fiduciary permits the transaction to proceed after receipt of the written disclosure.
Legal Costs According to 2012 Annual Return/Report of Employee Benefit (Form 5500) data and Internal Revenue Service Statistics of Income data, the Department estimates that there a…
81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
ose records if the disclosure would be precluded by 12 U.S.C. 484. A corresponding change was made in this exemption.
Back to Citation
48.
See e.g., PTE 2015-08, 80 FR 44753 (July 27, 2015) (Wells Fargo Company); PTE 2015-09, 80 FR 44760 (July 27, 2015) (Robert W. Baird & Co., Inc.); PTE 2014-06, 79 FR 3072 (July 24,…
81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
under section 4975 of the Code] is hereby transferred to the Secretary of Labor”).
Back to Citation
9.
29 CFR 2550.408b-2(e); 26 CFR 54.4975-6(a)(5). Back to Citation
10.
See
PTE 86-128, Exemption for Securities Transactions Involving Employee Benefit Plans and Broker-Dealers, 51 FR 41686 (November 18, 1986), as ame…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA).[352]
PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsDec 9, 2011
…ontracts in an amount equal to the Annuity
Value for purposes of Revenue Ruling 55-119, 1955-1 C.B. 352, and each Trust shall
recognize gain or loss as a result of such transfer in the tax year that includes such
transfer as provided therein.
2. Each Trust will recognize gain or loss as a result of the sale of its Part…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ent years
Activity
Burden hours
Equivalent
burden cost
Burden hours Equivalent
burden cost
Legal
10,352
$1,649,488
0
$0
Total
10,352
1,649,488
0
0
For the added requirement of a written statement informing the investor of their right to obtain a written description of the financial institution's policies and procedures…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
IRCCourt RulingsNov 5, 1999
…unt No. 015-268675 was as
follows:
- 11 -
Date
Withdrawal
Deposit
Balance
8/27/85 $1,333.20 --- $53,352.07
8/27/85 50,000.00 --- 3,352.07
10/15/85 --- $1,127.20 4,479.27
11/25/85 --- 1,333.20 5,812.47
12/03/85 5,500.00 673.91 986.38
1/13/86 14,500.00 13,654.49 140.87
4/14/86 --- 1,059.80 1,200.67
10/07/86 3.00 1,028.36…
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 RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
IRCCourt RulingsNov 4, 1998
…03(h), 706(g)(1), and
717(a), (b), and (c) of title VII of the Civil Rights Act of
1964, Pub. L. 88-352, 78 Stat. 254, 257, 261, as amended. The
opinion concludes that “employee” as used in section 704(a) of
Pub. L. 88-352, 78 Stat. 257, is ambiguous and further concludes
that the purposes of that section 704(a) would …
IRCCourt RulingsJun 9, 1965
…ed goods.. 353,677.93 111,687.77 324,986.69 353,677.93 111, 687.77 324,986.69
Total inventory.. 790,352.39 790,352.39
DEFERRED CHARGES
Factory supplies.— Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14
Total deferred charges. 13,049.01 13,049.01
FIXED ASSETS
IRCCourt RulingsApr 15, 1991
…. 1982).
United States v. Williams, 737 F.2d 594 (7th Cir. 1984).
O’Malley v. Commissioner, 91 T.C. 352 (1988).
Since we have previously held petitioner’s legal expenses to be personal in nature, petitioner is estopped from now arguing that the legal fees were incurred in his capacity as fiduciary of the pension plan. …
89 FR 64538 — Quality Control Standards for Automated Valuation Models IRCFinal Rules (FR)Aug 7, 2024
…3909; 15 U.S.C. 1681s, 1681w, 6801 and 6805. 4. Add subpart O, consisting of §§ 225.350 through 225.352, to part 225 to read as follows:
Subpart O—Quality Control Standards for Automated Valuation Models Used for Mortgage Lending Purposes
225.350
Authority, purpose and scope.
225.351
Definitions.
225.352
Quality contro…