88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements IRCProposed Rules (FR)Proposed Aug 30, 2023★ strong match
r administrative personnel who also perform duties of a manual or physical nature, in the construction, alteration, or repair of a qualified facility. The proposed regulations would provide that the type of construction would be the general category of construction as established by the DOL for the publication of gener…
IRCFinal Rules (FR)Apr 9, 2018
…nsactions.” Under the proposed definition, a commercial real estate transaction would have included construction loans for 1-to-4 family residential units, but not those providing permanent financing. Accordingly, the proposed definition would have included a loan extended to finance the construction of a consumer's dw…
IRCProposed Rules (FR)Proposed Dec 3, 2007related by meaning
… regulations prescribed by the Secretary of Labor under section 404(c)(5) of ERISA. (c) Permissible withdrawal—(1) In general. If the plan provides, any employee who has default elective contributions made under the eligible automatic contribution arrangement may elect to make a withdrawal of such contributions (and ea…
PLR 201129029 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 22, 2011related by meaning
…ance. Rev. Rul. 87-117, 1987-2 CB 61, involves a regulated public utility that abandons
a partially-completed nuclear plant; the ratemaking authority allow s a rate increase that
takes into account the cost of the abandoned plant. The ruling holds that the rate
increase does not reduce the taxpayer's abandonment-loss d…
IRCFinal Rules (FR)May 23, 2022★ strong match
hich withdrawal liability calculations should be considered when determining the equivalent single interest rate that produced the same result (
i.e., is it based on when the withdrawal liability amount is assessed or when the employer withdrew). In response, the Agencies are revising this question and instructions in …
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…or the
payment of vacation pay does not, in and of itself, prevent the accrual and deduction of
the liability for the year in which the liability is established. The ruling also suggests that
a use-or-lose provision will not prevent accrual of the liability, because it states as a fact
that "[t]he liability of the corp…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026related by meaning
…elines during requests for information.
One commenter, while generally supportive of establishing a withdrawal process, opposed the proposed ability of the non-initiating party to deny a withdrawal request and indicated that the initiating party should have the ability to unilaterally withdraw a dispute at any time pri…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
… in the applicable instructions. (iv) Disregarded for purposes of section 402(g). The amount of the withdrawal is not taken into account in determining the limitation on elective deferrals under section 402(g).
(2) Forfeiture of matching contributions. In the case of any withdrawal made under paragraph (c) of this sect…
IRCRegulationsMay 18, 2016related by meaning
(b)(3) (3) Any payment to a multiemployer plan for withdrawal liability imposed under part 1 of subtitle E of title IV of ERISA. Any bond or escrow payment furnished under such part shall not be considered as a payment of liability until applied against the liability of the employer.
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
…w comment to clarify the exemption in § 1026.35(c)(2)(iv) for “a transaction to finance the initial construction of a dwelling.” Specifically, new comment 35(c)(2)(iv)-2 clarifies that the exemption for construction loans in § 1026.35(c)(2)(iv) applies to temporary financing of the construction of a dwelling that will …
IRCCourt RulingsMar 24, 1993
…p constitute one of the world’s largest and most diversified oil field services and engineering and construction organizations. Halliburton’s business is divided into three principal categories: Oil field services and products, industrial engineering and construction services, and marine engineering and construction se…
I.R.C. § 432(g) — Additional funding rules for multiemployer plans in endangered status or critical status IRCCode / StatuteJan 6, 2025related by meaning
(g) (g) Adjustments disregarded in withdrawal liability determination
(g)(1) (1) Benefit reduction Any benefit reductions under subsection (e)(8) or (f), or benefit reductions or suspensions while in critical and declining status under subsection (e)(9), unless the withdrawal occurs more than ten years after the effect…
Rev. Rul. 2007-43 — Section 411(d)(3); partial termination; turnover. This ruling holds that based on its facts and circumstances, there is a presumption of a partial termination … IRCRevenue RulingsJul 9, 2007
…where the turnover rate is less than 20 percent. In the present case, there is a presumption that a partial termination has occurred because the turnover rate is 20 percent or more. The facts and circumstances support the finding of a partial termination because the severances from employment occurred as a result of th…
IRCRegulationsSep 9, 2016related by meaning
(d) (d) Consequences of the withdrawal
(d)(1) (1) Income tax consequences
(d)(1)(i) (i) Year of inclusion. The amount of the withdrawal is includible in the eligible employee's gross income for the taxable year in which the distribution is made. However, any portion of the distribution consisting of designated Roth con…
IRCCourt RulingsJun 14, 2012
…n Construction, Mr. Repetto, and Mrs. Repetto
formed Ozark Future, L.L.C. (Ozark Future), a limited liability company classified
as a partnership for Federal income tax purposes. Porschen Construction had a
IRCCode / StatuteJan 6, 2025related by meaning
(b)(7)(A) (A) Withdrawal liability Any amount received by a multiemployer plan in payment of all or part of an employer's withdrawal liability under part 1 of subtitle E of title IV of the Employee Retirement Income Security Act of 1974 shall be considered an amount contributed by the employer to or under the plan. The…
IRCRegulationsSep 9, 2016related by meaning
(d)(2) (2) Withdrawal of mandatory contribution
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
… grading
required for the northern portion lots. It is also materially shorter than t he three-year construction period assumed for the full 56-lot
subdivision.
We therefore assume a development timeline of two years: one
year for permitting and final-map recordation, followed by one year of
construction. We further as…
IRCRegulationsMay 18, 2016related by meaning
(b)(2)(ii)(B) (B) Overpayment of withdrawal liability. In the case of an overpayment of withdrawal liability established by the plan sponsor under section 4219(c)(2) of ERISA, the plan will not fail to satisfy section 401(a)(2) if, in accordance with Pension Benefit Guaranty Corporation regulations regarding the overpa…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
…ney was to be paid by the bank directly to petitioner’s subcontractor who was to perform the actual construction work on the facilities. In its income tax returns for the years involved herein, petitioner failed to include in its gross income the full amount of the payments made by the Government under the contract, al…