71 T.C. 765 — Elliot Knitwear Profit Sharing Plan v. Commissioner IRCCourt RulingsFeb 12, 1979
…om the securities purchased on margin is taxable under section 511. His argument focuses on section 514. He argues that the securities are debt-financed property within the meaning of section 514(b)(1); as such, the income from the*181 securities is unrelated debt-financed income under section 514(a) and thus is taxabl…
85 FR 77952 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCFinal Rules (FR)Dec 2, 2020
…cause of the interaction between section 512(b)(13) and the debt-financed property rules of section 514. For example, one commenter provided a series of examples in which a wholly owned taxable subsidiary rented space from its exempt organization parent in a debt-financed property owned by the parent.
Section 1.514(b)-…
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…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021★ strong match
…
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…
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
cribed in § 4947(a)(2) because it has no amounts in trust for which a deduction was allowed under § 170, 545(b)(2), 642(c), 2055, 2106(a)(2), or 2522. (63) Section 6109.—Identifying Numbers.—The proper assignment or retention of an employer identification number (EIN) in the case of a reorganization within the meaning …
90 FR 3092 — Automatic Enrollment Requirements Under Section 414A IRCProposed Rules (FR)Proposed Jan 14, 2025
… that the Department of Labor anticipates that the notice requirements of sections 404(c)(5)(B) and 514(e)(3) of ERISA and sections 401(k)(13)(E) and 414(w)(4) of the Code could be satisfied in a single disclosure document.
See72 FR 60455 (regarding the notice requirements under section 404(c)(5)(B) of ERISA and sectio…
85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCProposed Rules (FR)Proposed Apr 24, 2020
…(6).
a. Unrelated Debt-Financed Income In the case of debt-financed property (as defined in section 514), section 512(b)(4) requires an exempt organization to include, as an item of gross income from an unrelated trade or business, any unrelated debt-financed income, determined under section 514, with respect to such d…
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.
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…
IRCCourt RulingsJan 17, 2024related by meaning
United States Tax Court
T.C. Memo. 2024-6
CLAIR R. COUTURIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed January 17, 2024.
—————
Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and
Jonathan T. Amitrano , for petitioner.
Hilary E. March , Laura A. Pr…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016related by meaning
................................................ 494
.08 Penalty of perjury statement ............................................................ 494 .09 Procedural Requirements Checklist . . .. . .. . .. . .. . .. . .. . ......................... 494
.10 Orphan Plan ... . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
tion or Section 4947(a)(1) Trust Treated as Private Foundation, if the organization is required to file at least 250 returns during the calendar year. Section 6011(e)(4) was added to the Code in 2010 by section 522, Title V, of the Hiring Incentives to Restore Employment (HIRE) Act, Public Law 111-147, 124 Stat. 71, to…
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…health insurance issuers would generally constitute a “specified state law” notwithstanding section 514 of ERISA and would continue to apply. While section 514(b)(2)(A) saves from ERISA preemption state laws regulating insurance, section 514(b)(2)(B) of ERISA, referred to as the “deemer clause,” provides that a state l…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
IRCProposed Rules (FR)Proposed Dec 3, 2007★ strong match
… (DOL) has interpretative jurisdiction for that notice. Section 902 of PPA ’06 also amended section 514 of ERISA to preempt any State law which would directly or indirectly prohibit or restrict the inclusion in any plan of an automatic contribution arrangement. The Secretary of Labor is authorized to prescribe regulati…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…as follows: Authority: Secs 2701 through 2763, 2791, and 2792, of the Public Health Service Act, 42 USC 300gg through 300gg-63, 300gg-91, 30gg-92 as amended by HIPAA (Public Law 104-191, 110 Stat. 1936), MHPA (Public Law 104-204, 110 Stat. 2944, as amended by Public Law 107-116, 115 Stat. 2177), NMHPA (Public Law 104-2…
IRCCourt RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
IRCCourt RulingsMay 30, 1984related by meaning
ents of section 2039(c)(3).
Due to concessions and in order to reflect petitioner’s claim for an overpayment,
Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
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.