Treas. Reg. § 1.407-1(c)(1)(ii) — Treatment of certain employees of domestic subsidiaries engaged in business outside the United States as employees of the domestic parent corporation. IRCRegulationsMay 18, 2016
… (including individuals treated as employees of the domestic parent corporation pursuant to section 407 and this section).
(c)(2) (2) Determination of compensation. For purposes of applying section 401(a) (5) and the regulations thereunder, relating to classifications that will not be considered discriminatory, with re…
IRCCourt RulingsSep 30, 1991
…be decided whether the subject property constituted qualifying employer real property under section 407(d)(4) of ERISA. Section 407(d)(4) of ERISA defines “qualifying employer real property” as parcels of “employer real property” if a substantial number of parcels are dispersed geographically. In addition, each parcel …
IRCCourt RulingsJun 1, 1987
…ease transactions did not concern “qualifying employer real property” within the meaning of section 407(d)(4) of ERISA. Petitioners’ assertion is conditioned upon the determination as to whether the subject lease transactions concern “employer real property” within the meaning of section 407(d)(2) of ERISA and, if so, …
IRCPrivate Letter RulingsMar 2, 2001
…ed person. ERISA §408(e), in turn, cites the definition of qualifying employer
securities in ERISA §407(d)(5). Bas ed upon these provisions, the Department of
Labor has concluded, and we concur, that for purposes of meeting the exemption
under §4975(d)(13) the definition of “qualif ying employer securities” in §407(d)(…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsDec 19, 2000★ strong match
…res set
forth in sections 6221 through 6231; i.e., the TEFRA partnership
provisions. See TEFRA sec. 407(a)(1), 96 Stat. 670. Under TEFRA
section 407(a)(3), 96 Stat. 670, the TEFRA procedures may also
apply to partnership taxable years beginning before the September
3, 1982, effective date. TEFRA section 407(a)(3) provi…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsOct 18, 2002
…s) 14,473.86 19,902.36
Line 15a. Total IRA distributions $85,630.90 ---
Line 15b. Taxable amount 21,407.73
[2]
21,407.50
Line 33. Adjusted gross income 43,127.58 48,742.89
1
In 1998, petitioners originally reported $1,016.20 of interest income
but actually received only $980. See supra
note 2.
2
We note that in 1999 pe…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsJun 30, 1982related by meaning
ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
IRCCourt RulingsMay 23, 1979related by meaning
petitioner sought to deduct, as the sole shareholder, the entire net operating loss of $16,946.11 for the initial short taxable year on his Form 1040. We held in Bianchi that the contribution, including the compensation paid to petitioner during the initial 7-day taxable year, was unreasonable and properly disallowed, …
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsDec 8, 1987
…he acquisition, sale, or lease by a plan of qualifying employer real property as defined in section 407(d)(4) of ERISA. To be exempt, such acquisition, sale, or lease must be for adequate consideration, no commission must be charged for arranging such transaction, and the plan involved must be an eligible individual ac…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
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
ry 1, 2026 is $407,143. Therefore, the remuneration attributable to services performed by K in J’s 2024 taxable year is $80,612 ($407,143 - $326,531). (xi) As of December 31, 2025, K has a right to a $500,000 payment on January 1, 2026 ($500,000 x 10% x 10 years of service). The present value as of December 31, 2025 of…