88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023
…C.-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insurance.
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
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
…d to the outdoor advertising display, constitutes real property for purposes of § 856.
(45) Section 1031(f).—Special Rules for Exchanges Between Related Persons.—Except in the case of (i) a transaction involving an exchange of undivided interests in different properties that results in each taxpayer holding either the …
IRCCourt RulingsAug 31, 1964★ strong match
… received without the recognition of gain or loss, but also of other property or money, see section 1031 (b) and (c) and the regulations thereunder. Such an exchange does not come within the provisions of section 1035. Determination of the basis of property acquired in an exchange under section 1035(a) shall be governe…
PLR 200711014 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsMar 16, 2007★ strong match
…7, 83rd Cong., 2d Sess. 81 (1954).
Thus, section 1035 operates as the insurance analogue to section 1031, which relates
to like-kind exchanges of certain types of prop erty held for productive use in a trade or
business or for investment. The similarity of sections 1031 and 1035 is evidenced in
IRCCourt RulingsDec 24, 1985related by meaning
terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange.
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
…rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
… HHS and Transportation ability to conduct these analyses.
E. Regulatory Flexibility Act The RFA (5 USC 601, et seq.), requires agencies to prepare an initial regulatory flexibility analysis to describe the impact of these proposed rules on small entities, unless the head of the agency can certify that the rule will no…
IRCCourt RulingsFeb 9, 2023related by meaning
gross income, deductions, credits, or allowances
between or among such organizations, trades, or
businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to
prevent evasion of taxes or clearly to reflect the income of
any of such organizations, trades, or businesses. In t…
IRCCourt RulingsJan 28, 2014related by meaning
way of
providing employees with some measure of flexibility with regard to their
retirement planning. However, Congress added the section 408(d)(3)(B) limitation as a way to ensure that taxpayers did not take advantage of section
408(d)(3)(A) to repeatedly shift nontaxable income in and out of retirement
accounts. See,…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
IRCCode / StatuteJan 6, 2025related by meaning
(q)(3)(B)(ii) (ii) an exchange of all or a portion of such contract for another contract is made under section 1035, and
(q)(3)(B)(iii) (iii) the aggregate distributions from the contracts involved in the exchange continue to satisfy the requirements of paragraph (2)(D) as if the exchange had not taken place,
PLR 202625002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJun 18, 2026
…ty contract.
Section 1035(d)(1) provides that if an exchange is not solely in kind, the rules of
§§ 1031(b) and (c) should apply.
Section 1031(b) and (c) apply if an exchange would be within the provisions of
§ 1035(a), if it were not for the fact that the property received in exchange consists not
only of property per…
PLR 202625003 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJun 18, 2026
…ty contract.
Section 1035(d)(1) provides that if an exchange is not solely in kind, the rules of
§§ 1031(b) and (c) should apply.
Section 1031(b) and (c) apply if an exchange would be within the provisions of
§ 1035(a), if it were not for the fact that the property received in exchange consists not
only of property per…
IRCPrivate Letter RulingsJun 17, 2016related by meaning
for another annuity contract. The legislative history of § 1035
explains that § 1035 provides non-recognition treatment for taxpayers who have “merely exchanged an [annuity contract] for another better suited to their needs and who have
not actually realized gain.” H. Rep. 1337, 83d Cong., 2d Sess. 81 (1954). Un der
§ …
IRCCourt RulingsApr 10, 2000related by meaning
erty interest therein.
- 8 -
Recognition of community property interests in an IRA for
Federal income tax purposes would conflict with the application of section 408 in several ways. As an initial matter, an account
imbued with a community property characterization would have
difficulty meeting the IRA qualifications. …
Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex… IRCNoticesNov 13, 2007related by meaning
g whether an estate making the section 6166 election will be required to provide security.
TAX CONVENTIONS
Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
IRCCourt RulingsFeb 12, 2014related by meaning
o be
used for a qualified use. See Stovall v. Commissioner, 101 T.C. at 151.
We conclude here, as we did in Stovall, that it is appropriate to use the regulations under section 1033(a) as guidance in determining whether the Secretary was "notified" under section 4979A(e)(2)(D) of the ownership that gives rise
to the ex…