REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv… IRCProposed Rules (FR)Proposed May 28, 2013
…solidated group ending December 31, 2016, are not subject to the deduction limitation under section 162(m)(6). (g) Coordination—(1) Coordination with section 162(m)(1). If section 162(m)(1) and section 162(m)(6) would both otherwise apply with respect to the remuneration of an applicable individual, the deduction limit…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…, whenever those amounts become otherwise deductible
(g) Coordination—(1) Coordination with section 162(m)(1). If section 162(m)(1) and section 162(m)(6) both otherwise would apply with respect to the remuneration of an applicable individual, the deduction limitation under section 162(m)(6) applies without regard to se…
IRCProposed Rules (FR)Proposed Feb 18, 2025★ strong match
)-1(b) and 1.263A-1(c)(2).
2 The addition of section 162(m)(3)(C) resulted in pre-ARP section 162(m)(3)(C) being redesignated as section 162(m)(3)(D). 3 This interpretation is consistent with the description of section 162(m)(3)(C) by the Joint Committee on Taxation in General Explanation of the Tax Legislation Enacted…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
mal end.
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5.
The proposed regulations would redesignate existing § 1.170A-16(d)(3)(viii) to § 1.170A-16(d)(3)(x).
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6. In other words, a charitable contribution of more than $500 but not more than $5,000, § 1.170A-16(c), a charitable contribution of more than $5,000, § 1.170A-16(d), or …
78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013★ strong match
…payer may not have extended the due date.
(3)
Optional application of TD 9564. Except for section 1.162-3T(e), a taxpayer may choose to apply § 1.162-3T as contained in TD 9564 (76 FR 81060) December 27, 2011, to amounts paid or incurred (to acquire or produce property) in taxable years beginning on or after January 1,…
Notice 2011-2 — This notice provides guidance on the application of section 162(m)(6) of the Code. Section 162(m)(6) limits the allowable deduction for remuneration for servic… IRCNoticesJan 10, 2011
Notice 2011-2
Guidance on the Application of Section 162(m)(6)
I. PURPOSE
This notice provides guidance on the application of section 162(m)(6) of the Internal Revenue Code (Code). Section 162(m)(6) limits the allowable deduction for remuneration for services provided by individuals to certain health insurance provider…
89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCFinal Rules (FR)Jun 28, 2024related by meaning
Section 605(c)(2) of the SECURE 2.0 Act states that no inference is intended as to the appropriate treatment of any contribution for which a deduction is not disallowed by reason of section 170(h)(7). As explained in the preamble to the proposed regulations, some practitioners have taken the position that section 170(h…
T.D. 9716 — Section 162(m) generally limits the otherwise allowable deduction for compensation paid with respect to a covered employee of a publicly held corporation to no… IRCTreasury DecisionsApr 13, 2015★ strong match
…calendar year following the calendar year in which the corporation becomes publicly held. Section 1.162–27(f)(3) provides that the relief provided under § 1.162–27(f)(1) applies to any compensation received pursuant to the exercise of a stock option or stock appreciation right, or the substantial vesting of restricted …
Notice 2008-94 — This notice provides guidance on certain executive compensation provisions of the Emergency Economic Stabilization Act of 2008 (EESA). Section 302 of EESA adde… IRCNoticesNov 3, 2008
Notice 2008-94
Guidance for Sections 162(m)(5) and 280G(e) of the Internal Revenue Code
I. PURPOSE
This notice provides guidance on certain executive compensation provisions of the Emergency Economic Stabilization Act of 2008, Div. A of Pub. Law No. 110-343 (EESA), which was enacted on October 3, 2008. Section 302 of E…
86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCFinal Rules (FR)Jan 6, 2021
2 (FDIC) (“synthetic exposure”).
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32.
See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”).
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33.
See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC).
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Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
Applicability Date
Proposed § 48.6435-1 would apply to removals of eligible dyed fuel occurring on or after December 31, 2025. See section 7805(b)(2). Special Analyses
I. Regulatory Planning and Review
These proposed regulations are not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memor…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
ation
133.
Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)(
5), 29 CFR 2590.716-8(b)(2)(ii)(A)(
5), and 45 CFR 149.510(b)(2)(ii)(A)(
5).
Back to Citation
134. Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
T.D. 9932 — Section 162(m)(1) of the Internal Revenue Code generally limits to $1,000,000 the allowable deduction for a taxable year for applicable employee remuneration p… IRCTreasury DecisionsJan 19, 2021★ strong match
…lecting real property trade or business under section 163(j)(7)(B) of the Internal Revenue Code.
26 CFR 601.601. Rules and regulations.
Notice 2026-32 — This notice provides that a broker-dealer that carries customer accounts and receives or holds funds or securities for those customers may, in lieu of demonstr… IRCNoticesJun 15, 2026related by meaning
…rrangements (HRAs) provided under § 54.9831-1(c)(3)(viii) of the Pension Excise Tax Regulations.
26 CFR 601.602: Tax forms and instructions. (Also: Part I, §§ 1, 223, Part III § 54.9831-1)
EMPLOYEE PLANS
Notice 2026-32, page 1578.
This notice provides that a broker-dealer that carries customer accounts and receives or …
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
89 FR 4215 — Request for Information-SECURE 2.0 Section 319-Effectiveness of Reporting and Disclosure Requirements IRCProposed Rules (FR)Proposed Jan 23, 2024related by meaning
… a manner calculated to be understood by the average employee).
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26.
See, e.g.,29 CFR 2520.102-2(c) (describing standards for summary plan descriptions furnished to plan participants literate in a non-English language and assistance that must be provided to non-English speakers to inform them of their…
90 FR 23303 — Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule IRCProposed Rules (FR)Proposed Jun 2, 2025
.210(a)(2)(xi).
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20.
26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D).
21. The TiC final rules also clarify that nothing in 26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D) requires th…
89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern IRCFinal Rules (FR)May 6, 2024related by meaning
esses, such as International Traffic in Arms Regulations (ITAR) registration or National Institute of Standards and Technologies (NIST) certification. The Treasury Department and the IRS appreciate the commenters' desire for certainty regarding the procedures for establishing reasonable reliance and due diligence. As d…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016★ strong match
3(i) and 12 U.S.C. 5381(a)(3).
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24.
12 CFR part 50 (OCC), 12 CFR part 249 (Board), and 12 CFR part 329 (FDIC).
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25.
See 12 CFR 3.2 (OCC), 12 CFR 217.2 (Board), and 12 CFR 324.2 (FDIC).
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26.
See
section II.D and II.C of this
Supplementary Information
section for discu…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…ed under all industries and categories of
industries for companies that had sales of approximately $162
million:
Title
Year
Sales
Average
+1 SD
+2 SDs
All Industries
CEO 1989 $162.416 $340.72 $497.96 $655.21
All Manufacturing
CEO 1989 162.416 345.71 505.38 665.04
Durable Goods Manufacturing
CEO 1989 162.416 343.92 522.…