IRCPrivate Letter RulingsJun 11, 2004★ strong match
…t its method of accounting for (accelerating) deductions for employer contributions is described in Rev. Rul. 2002-46,
not Rev. Rul. 90-105. Therefore, IDR No. 10, citing Rev. Rul. 2002-46, placed
Taxpayer
‘s method of accounting under consideration. Taxpayer contends that it
applied for an automatic method change on J…
Rev. Rul. 2011-1 — This ruling modifies the rules for group trusts described in Rev. Rul. 81-100, 1981-1 C.B. 326, as clarified and modified by Rev. Rul. 2004-67, 2004-2 C.B. 28.… IRCRevenue RulingsModified Jan 10, 2011★ strong match
by reason of section 833(c)(5) of the Code. Rev. Proc. 2008-52 modified. Notice 2010-79 clarified and modified.
Rev. Proc. 2011-12 Rev. Proc. 2011-12 Cost-of-living adjustments for 2011. This procedure sets forth the 2011 cost-of-living adjustments to certain items due to inflation as required under various provisions…
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
…(b) and clarifies the ability of certain individual retirement accounts under § 408 to participate. Rev. Rul. 2011-1 extends the ability to participate in group trusts to custodial accounts under § 403(b)(7), retirement income accounts under § 403(b)(9), and governmental retiree benefit plans under § 401(a)(24). There …
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★ strong match
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
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
…ERMINATION LETTERS WILL NOT BE ISSUED UNTIL THE SERVICE RESOLVES THE ISSUE THROUGH PUBLICATION OF A REVENUE RULING, A REVENUE PROCEDURE, REGULATIONS, OR OTHERWISE
.01 Specific Questions and Problems.
(1) Sections 302 and 304.—Distributions in Redemption of Stock; Redemption Through Use of Related Corporations.—Treatmen…
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, 2006★ strong match
…ated return where member(s) of the group use a 52-53 week taxable year).
SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES Rev. Proc. 2005-3, 2005-1 C.B. 118, Rev. Proc. 2005-61, 2005-37 I.R.B. 507, and Rev. Proc. 2005-68, 2005-41 I.R.B. 694, are superseded.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective Jan…
Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014related by meaning
…nconstitutional because it violates Fifth Amendment principles. Subsequent to the Windsor decision, Rev. Rul. 2013–17 held the following: (1) For Federal tax purposes, the terms “spouse,” “husband and wife,” “husband,” and “wife” include an individual married to a person of the same sex if the individuals are lawfully …
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★ strong match
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Notice 2012-6 — This notice extends and expands the transition relief provided under Rev. Rul. 2011-1, 2011-2 I.R.B. 251, and Rev. Rul. 2008-40, 2008-2 C.B. 166, for certain g… IRCNoticesJan 17, 2012
(24) of the Internal Revenue Code (Code) (§ 401(a)(24) plans) to be amended to satisfy the applicable requirements of Rev. Rul. 2011-1.
II. BACKGROUND Rev. Rul. 81-100, 1981-1 C.B. 326, provides that qualified retirement plans and individual retirement accounts are permitted to pool their assets for investment purposes…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
Rul. 66-110, as amplified by Rev. Rul. 67-154, for periods after December 31, 2003, with respect to arrangements entered into after January 28, 2002. Rev. Rul. 2003-105, 2003-40 I.R.B. 696, obsoleted Rev. Rul. 66-110 for arrangements entered into after September 17, 2003, except as provided in paragraph 3 of Section I…
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, 2005★ strong match
…ERMINATION LETTERS WILL NOT BE ISSUED UNTIL THE SERVICE RESOLVES THE ISSUE THROUGH PUBLICATION OF A REVENUE RULING, REVENUE PROCEDURE, REGULATIONS OR OTHERWISE
.01 Section 62(c).—Reimbursement Arrangements.—Whether amounts related to a salary reduction and paid under a purported reimbursement or other expense allowance…
IRCCourt RulingsSep 30, 1985related by meaning
4). We do not find Rev. Rul. 69-647 intrinsically persuasive, and we agree with the Claims Court that it is distinguishable on its facts in any event. Of course, a distribution upon plan termination may be a ''qualifying rollover distribution” under sec. 402(a)(5)(D), and be rolled over into another qualifying plan.
Se…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…ement are included in the employee’s gross income, even amounts paid to reimburse medical care. See Rev. Rul. 2006-36, 2006-36 I.R.B. 353; Rev. Rul. 2005-24, 2005-1 C.B. 892; Rev. Rul. 2003-102, 2003-2 C.B. 559; Notice 2002-45, 2002-2 C.B. 93; Rev. Rul. 2002-41, 2002-2 C.B. 75; Rev. Rul. 69-141, 1969-1 C.B. 48. New sec…
Rev. Rul. 2004-67 — Group or pooled trusts; participation; tax-exempt status, model language. This ruling provides that a governmental section 457(b) plan may invest in a second t… IRCRevenue RulingsJul 12, 2004related by meaning
…mination letter issued to it prior to July 12, 2004, regarding eligibility of its group trust under Rev. Rul. 81-100 will not lose its right to rely on its determination letter merely because it adopts Model Amendment 1 set forth above in this revenue ruling on a word-for-word basis (or adopts an amendment that is subs…
Rev. Rul. 2014-9 — This revenue ruling provides simplified safe harbor due diligence procedures a plan administrator may use in order to be deemed to have reasonably concluded th… IRCRevenue RulingsApr 21, 2014related by meaning
…the decision in United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013), and the holdings of Rev. Rul. 2013–17, 2013–38 I.R.B. 201 (Sept. 16, 2013), to retirement plans qualified under section 401(a) of the Internal Revenue Code (Code). Rev. Rul. 2013–17 is amplified.
IRCCourt RulingsMay 27, 2010
…tar Plan, the applicable Federal rate was 3 .89 percent for a short-term loan compounded annually . Rev . Rul . 2005-66, 2005-2
C .B . 686 . Mid- and long-term rates were higher . Id . In March
2006, when Mogelefsky withdrew from Benistar Plan, the applicable
Federal rate .was 4 .58 percent for a short-term loan compou…
Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum… IRCRevenue RulingsNov 26, 2007related by meaning
…f 2007 applies to notices under section 6404(g)(1) that are provided on or after November 26, 2007.
Rev. Proc. 2007-67 Rev. Proc. 2007-67 Change in accounting method. This document allows taxpayers, under certain conditions, to request to revise the year of change for a Form 3115, Application for Change in Accounting M…
IRCCourt RulingsMar 26, 1979related by meaning
…s. * » * ”
(Emphasis added.)
See also S. Rept. 830, n. 6 supra. It is not without significance that Rev. Rul. 67-258 was not issued until several years after Congress had enacted sec. 72(m) specifically making taxable loans received by owner-employees. See p. 1056 supra. In this context, it appears that respondent has …
PLR 202417010 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsApr 26, 2024
t cause
Taxpayer to fail to qualify as an 81-100 group trust within the meaning of Rev. Rul.
2011-1.
LAW AND ANALYSIS
Rev. Rul. 81-100, as modified,
1 provides that certain retiree benefit plans and other
arrangements are permitted to pool their assets for investment purposes in an “81-100
group trust” if certain speci…
IRCPrivate Letter RulingsMar 16, 2018related by meaning
…and accompanied by a penalty of perjury statement executed by an appropriate party, as specified in Rev. Proc. 2017-1, 2017-1 I.R.B. 1,
§ 7.01(15)(b). This office has not verified any of the material submitted in support of the
request for ruling, and such material is subject to verification on examination. The
Associa…