IRCCourt RulingsFeb 9, 2023★ strong match
osed
regulations related to section 482 of the Internal Revenue Code of 1954,
was published in the Federal Register. 30 Fed. Reg. 4256 (filed Mar. 31, 1965). Under the proposal a new paragraph (d) would be added to
section 1.482-1 of the 1962 regulations, which had only three
paragraphs: (a), (b), and (c). The proposed…
IRCRegulationsNov 22, 2024related by meaning
(f) (f) Rule of construction. Nothing in this section or § 54.9812-1 shall be construed to prevent the Secretary from acting within the scope of existing authorities to address violations of § 54.9812-1 or this section.
IRCRegulationsJul 26, 2016related by meaning
(ii)(3) (3)
IRCRegulationsDec 30, 2016related by meaning
(a) (a) [Reserved]
IRCRegulationsAug 3, 2026related by meaning
(b) (b) For further guidance, see 29 CFR 2590.716-3.
IRCProposed Rules (FR)Proposed May 13, 2026related by meaning
Similarly, the proposed notice requirements at paragraphs (c)(3)(ix)(D) of 26 CFR 54.9831-1, and 29 CFR 2590.732 and paragraph (b)(3)(ix)(D) of 45 CFR 146.145 are separate requirements that can stand independently of the standards under paragraphs (c)(3)(ix)(A), (B), and (C) of 26 CFR 54.9831-1, and 29 CFR 2590.732 and…
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
…fication of a new clean vehicle determined consistent with the rules and definitions provided in 40 CFR 600.315-08 and this paragraph (b)(56) for vans, sport utility vehicles, pickup trucks, and other vehicles.
(ii)
Van.
Van means a vehicle classified as a van or minivan under 40 CFR 600.315-08(a)(2)(iii) and (iv), or …
IRCCourt RulingsMay 22, 2025
…e methods.” Id. para. (g)(1). “Each method must be applied
in accordance with the provisions of § 1.482-1, including the best method rule of § 1.482-1(c), the comparability analysis of § 1.482-1(d), and the
arm’s length range of § 1.482-1(e), except as those provisions are
modified in this paragraph (g).” Temp. Treas. …
IRCRegulationsDec 30, 2016related by meaning
(a) (a) -(c) [Reserved]
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
IRCRegulationsSep 13, 2021related by meaning
(a) (a) Statutory basis. This section and §§ 54.9801-2 through 54.9801-6, 54.9802-1, 54.9802-2, 54.9802-3T, 54.9802-4, 54.9811-1, 54.9812-1, 54.9815-1251, 54.9815-2704, 54.9815-2705, 54.9815-2708, 54.9815-2711, 54.9815-2712, 54.9815-2713, 54.9815-2713A, 54.9815-2714, 54.9815-2715, 54.9815-2715A1, 54.9815-2715A2, 54.981…
IRCCourt RulingsJan 13, 1958related by meaning
This subsection shall be applicable to all contracts and subcontracts, to the extent of amounts received or accrued thereunder in any fiscal year ending after June 30, 1943, whether such contracts or subcontracts were made on, prior to, or after the date of the enactment of the Revenue Act of 1943, and whether or not s…
Notice 2004-8 — Roth IRAs; abuses; listed transactions. This notice describes certain transactions that are being entered into by individuals, their Roth IRAs, and their busin… IRCNoticesJan 26, 2004
… 370 F.2d 713 (1st Cir. 1966). Depending on the facts of the specific case, the Service may apply § 482 to allocate income from the Roth IRA Corporation to the Taxpayer, Business, or other entities under the control of the Taxpayer. Section 482 provides the Secretary with authority to allocate gross income, deductions,…
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
(104) Section 1362(f).—Inadvertent Invalid Elections or Terminations.—Principal purpose determinations regarding the one class of stock requirement.— Addressing the validity or continuation of an S election in situations regarding the one class of stock requirement that require a determination of the existence of a pri…
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).
Back to Citat…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023related by meaning
…(
TMA IV).
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9.
88 FR 65888 (Sept. 26, 2023).
Back to Citation
10. 86 FR 36888; 26 CFR 54.9816-6T(d)(1)(iii), 29 CFR 2590.716-6(d)(1)(iii), and 45 CFR 149.140(d)(1)(iii). For guidance regarding the certification statement in light of the decision in
TMA III, see
U.S. Department of Health and Human Serv…
IRCRegulationsDec 30, 2016related by meaning
(b) (b) [Reserved]
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
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
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
; Stevens Pass, Inc., 48 T.C. 532, 541 (1967); cf. Westinghouse Broadcasting Co., supra; but see fn. 7, supra.
Decision will be entered under Bule 50. Sec. 416 was reenacted without significant change by Pub. L. 85-861, 85th Cong., 2d Sess. (1958), 72 Stat. 1458, and is set forth as follows in 10 U.S.C. sec. 2388:
Sec.…