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56 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. REG-141075-09 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 …
    IRCProposed Rules (FR)Proposed Jun 18, 2012related by meaning
    REG-141075-09 Notice of Proposed Rulemaking Property Transferred in Connection with the Performance of Services Under Section 83 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations relating to property transferred in connection wi…
  2. 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.
  3. 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
    …f the contractual obligation. (97) Section 1001.—See section 3.01(13) and (14), above. (98) Section 1033.—Involuntary Conversions.—Whether the replacement or proposed replacement of compulsorily or involuntarily converted property does or does not qualify under § 1033(a), if the taxpayer has already filed a Federal tax…
  4. 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
    tment of section 30D(g) (that is, August 16, 2022) pursuant to section 104 of the Federally Recognized Indian Tribe List Act of 1994 (25 U.S.C. 5131). Section 30D(g)(10) provides that in the case of any taxpayer who has made a credit transfer election with respect to a new clean vehicle and received a payment from an e…
  5. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014★ strong match
    …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 excise tax under section 4979A(a).'° 9Sec. 1034 was repealed effective May 6, 1…
  6. 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…
  7. 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
    nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A). (48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
  8. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016★ strong match
    …at "[a] taxpayer need not make an affirmative election regarding the nonrecognition of gain under § 1033(a) of the 1954 Code." But what petitioner neglects to mention is that the following sentence in that decision reads: "The regulations explicitly state that a failure to include gain on an involuntary conversion in g…
  9. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
  10. 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…
  11. 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
    nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A). (48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
  12. 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.
  13. 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…
  14. T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations …
    IRCTreasury DecisionsAug 6, 2007related by meaning
    to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns. T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
  15. 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.
  16. 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…
  17. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    … in Phi Delta Theta Fraternity v. Commissioner , 887 F.2d 1302, 1307 (6th Cir. 1989), affg. 90 T.C. 1033 (1988): “Section 512(a)(3)(B), however, does allow reasonable costs actually spent in administering a tax-exempt activity to be included in ‘exempt function income.’” We find the Trustee’s reliance on that statement…
  18. 42 T.C. 993 — Barrett v. Commissioner
    IRCCourt RulingsAug 31, 1964related by meaning
    ermination of the basis of property acquired in an exchange under section 1035(a) shall be governed by section 1031(d) and the regulations thereunder. SEC. 72(E). AMOUNTS NOT RECEIVED AS ANNUITIES.— (1) General rule. — If any amount is received under an annuity, endowment, or life insurance contract, if such amount is …
  19. 68 T.C. 433 — Newman v. Commissioner
    IRCCourt RulingsJun 29, 1977
    …hich was to aid States in borrowing funds. Thus, in American Viscose Corp. v. Commissioner, 56 F.2d 1033 (3d Cir. 1932), affg. 19 B.T.A. 937 (1930), cert. denied 287 U.S. 615 (1932), it was stated:
  20. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …412(c)(3), 6059, and 7701(a)(35) were added to the Internal Revenue Code by ERISA sections 1013(a), 1033(a), and 3043, 88 Stat. 914, 947, 1003, to apply for plan years beginning after December 31, 1975. ERISA had a significant impact on pension plans, and one of its objectives was to place reliance upon enrolled actuar…