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
…n.—All situations in which an S corporation qualifies for automatic late S corporation relief under Rev. Proc. 2013-30, 2013-36 I.R.B. 173. .07 Sections 1502, 1504, and 1552.—Regulations; Definitions; Earnings and Profits.—All requests for waivers or consents on consolidated return issues where the Service has provided…
Rev. Proc. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresModified Jan 2, 2013★ strong match
ons, issues determination letters involving §§ 401, 403(a), 409, and 4975(e)(7) as provided in Rev. Proc. 2013-6, page , this Bulletin.
Opinion letter .05 An “opinion letter” is a written statement issued by the Service to a sponsor or M&P mass submitter as to the acceptability of the form of an M&P plan under § 401(a)…
Rev. Proc. 2014-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresJan 2, 2014★ strong match
…) of the Employee Retirement Income Security Act of 1974 (ERISA) that reduces accrued benefits, see Rev. Proc. 94–42, 1994–1 C.B. 717.
(2) For requests for a waiver of the minimum funding standard, see Rev. Proc. 2004–15, 2004–1 C.B. 490.
(3) For requests for a waiver of the 100 percent tax imposed under § 4971(b) of t…
Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of … IRCRevenue ProceduresModified Dec 29, 2025★ strong match
contrary to the position advanced? See section 6.02(7), which states that taxpayers must inform the Service of such authorities.
Yes No N/A Page ____ 17. If you determined that there are no contrary authorities, have you included a statement to this effect in your request? See section 6.02(7).
Yes No N/A Page ____
18.…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
…ter will also be issued as to the acceptability of the form of a prototype plan under § 403(b). See Rev. Proc. 2015–36, 2015–27 I.R.B. 20, (M&P plans) and Rev. Proc. 2013–22, 2013–18 I.R.B. 985, as modified by Rev. Proc. 2014–28, 2014–16 I.R.B. 944 and Rev. Proc. 2015–22, 2015–11 I.R.B. 754. See also Rev. Proc. 87–50, …
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019★ strong match
…mitted with respect to cycles prior to the third six-year remedial amendment cycle are contained in Rev. Proc. 2015–36. (2) The procedures for obtaining opinion letters for pre-approved plans submitted with respect to the third (and subsequent) six-year remedial amendment cycles are contained in Rev. Proc. 2017–41.
(3)…
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
…or trust instrument provides for the substitution of a custodian or trustee?
1 For purposes of this revenue procedure, references to Rev. Proc. 2016-37 are to Rev. Proc. 2016-37, as modified by Rev. Proc. 2017-41, 2017-29 IRB 92, Rev. Proc. 2020-40, 2020-38 IRB 575, and Rev. Proc. 2021-38, 2021-38 IRB 425, but not as m…
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006related by meaning
…tember 1, 2006.
SECTION 17. PAPERWORK REDUCTION ACT The collection of information contained in this revenue procedure has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545-1673.
An agency may not conduct or sponsor…
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
forth in Rev. Proc. 2017-41, and (b) the fourth six-year remedial amendment cycle for defined contribution plans are set forth in Rev. Proc. 2023-37. (2) The procedures for obtaining opinion letters for prototype trusts, custodial accounts, or annuities under § 408(a), (b), (k), or (p), or § 408A, are set forth in Rev…
Rev. Proc. 2003-72 — EP determination letters; extension of application deadline for certain pre-approved plans. This procedure extends the deadline for filing EP determination let… IRCRevenue ProceduresSep 22, 2003related by meaning
…etter, prior to the 91st day following issuance of the letter.
SECTION 8. EFFECT ON OTHER DOCUMENTS Rev. Proc. 2000-20, Rev. Proc. 2002-29, and Rev. Proc. 2003-44 are modified.
SECTION 9. EFFECTIVE DATE
This revenue procedure is effective September 22, 2003.
DRAFTING INFORMATION
The principal author of this revenue pro…
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
ow and Rev. Proc. 2021–1, this Bulletin.
SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES?
Pre-approved plans
.01 (1) The procedures for obtaining opinion letters for M&P plans and advisory letters for VS plans, and any related trusts or custodial accounts under §§ 401(a), 403(a), a…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024★ strong match
…tion qualified pre-approved plans and defined benefit qualified pre-approved plans are set forth in Rev. Proc. 2023-37. (2) The procedures for obtaining opinion letters for prototype trusts, custodial accounts, or annuities under § 408(a), (b), (k), or (p), or § 408A, are set forth in Rev. Proc. 87-50; Rev. Proc. 91-44…
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018★ strong match
ow and Rev. Proc. 2018–1, this Bulletin.
SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES?
Pre-approved plans
.01 (1) The procedures for obtaining opinion letters for M&P plans and any related trusts or custodial accounts under §§ 401(a), 403(a), and 501(a), and advisory letters for…
Rev. Proc. 2015-28 — This revenue procedure contains modifications to Revenue Procedure 2013–12, 2013–4 I.R.B. 313. The modifications reflected in this revenue procedure include ne… IRCRevenue ProceduresApr 20, 2015related by meaning
2013–12 is modified by this revenue procedure.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective April 2, 2015.
SECTION 7. PUBLIC COMMENTS The Treasury Department and the Service invite comments on this revenue procedure. Send submissions to CC:PA:LPD:PR, (Rev. Proc. 2015–28), Room 5203, Internal Revenue Se…
IRCCourt RulingsFeb 9, 2023
…. See § 1.482-2(d).
Sec. 1.482-1(b)(1), Proposed Income Tax Regs., 57 Fed. Reg. 3578-3579
(Jan. 30, 1992).
The 1992 proposed regulations also contained proposed
replacements to the tran sfer-pricing rules applicable to intangible
property in section 1.482-2(d) of the 1968 regulations. 33 Fed. Reg. 5852
(Apr. 16, 1968);…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
ion letters, see, respectively, section 8 of Rev. Proc. 2006-4 (this Bulletin) and section 3.02 of Rev. Proc. 2006-6 (this Bulletin).
.02 Changes.
(1) New section 3.01(3) (Sections 61, 451, and 1001.—Gross Income Defined...) has been added. See Rev. Proc. 2005-61, 2005-37 I.R.B. 507.
(2)
Section 3.01(9) (Section 105(h)…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016related by meaning
compensation” pursuant to Rev. Rul. 2002–27, 2002–1 C.B. 925. For rules relating to a failure to adopt a Good Faith Amendment, see Rev. Proc. 2013–12. (B) “Interim Amendment” means an amendment with respect to a disqualifying provision that results in the failure of the plan to satisfy the qualification requirements of…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
ow and Rev. Proc. 2020–1, this Bulletin.
SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES?
Pre-approved plans
.01 (1) The procedures for obtaining opinion letters for M&P plans and advisory letters for VS plans, and any related trusts or custodial accounts under §§ 401(a), 403(a), a…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005related by meaning
ion letters, see, respectively, section 8 of Rev. Proc. 2005-4 (this Bulletin) and section 3.02 of Rev. Proc. 2005-6 (this Bulletin).
.02 Changes.
(1) New section 3.01(2) (Section 61—Gross Income Defined) has been added.
(2)
Section 3.01(14) (Section 121—Exclusion of Gain from Sale of Principal Residence) has been modi…
Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2022
…mitted with respect to cycles prior to the third six-year remedial amendment cycle are contained in Rev. Proc. 2015-36. (2) The procedures for obtaining opinion letters for pre-approved plans submitted with respect to the third six-year remedial amendment cycle (and subsequent cycles) are set forth in Rev. Proc. 2017-4…