86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021related by meaning
lve the complaint.
Department of the Treasury
Internal Revenue Service
Accordingly, 26 CFR part 54 is amended as follows:
PART 54—PENSION EXCISE TAXES Paragraph 4. The authority citation for part 54 continues to read, in part, as follows:
Authority:
26 U.S.C. 7805, unless otherwise noted.
* * * * *
Par. 5. Section 54.9…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
er means and the transferor was, in fact, a foreign person, then the transferee is subject to the liability imposed by section 1445 and § 1.1445-1(e). (i) A transferee is in no event required to rely upon other means to ascertain the non-foreign status of the transferor and may demand a certification of non-foreign sta…
IRCCode / StatuteJan 12, 2018related by meaning
(e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee.
(e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or
(e)(12)(B) (B) the Secretary notifies …
T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409… IRCTreasury DecisionsJan 18, 2005related by meaning
INCOME TAX
Rev. Rul. 2005-3 Rev. Rul. 2005-3
Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
IRCCourt RulingsFeb 18, 1998related by meaning
statutory provisions and the
legislative histories of those provisions, we hold that
petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA
does not constitute a tax-free rollover contribution under
section 402(c) or 408(d)(3), respectively.
3
…
75 FR 46844 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Aug 4, 2010related by meaning
on 53.6071-1 is amended by revising paragraph (g)(3) to read as follows:
§ 53.6071-1
Time for filing returns.
* * * * *
(g) * * *
(3)
Transition rule. A Form 4720, for a section 4965 tax that was due on or before October 4, 2007, will be deemed to have been filed on the due date if it was filed by October 4, 2007, and …
IRCCode / StatuteJan 5, 2023related by meaning
(j) (j) Undisclosed foreign financial asset understatement
(j)(1) (1) In general For purposes of this section, the term "undisclosed foreign financial asset understatement" means, for any taxable year, the portion of the understatement for such taxable year which is attributable to any transaction involving an undisclo…
IRCCourt RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
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
blic hearing on the proposed regulations is scheduled for October 24, 2007. Rev. Rul. 2001-48 and Notice 2006-43 modified.
REG-138707-06 REG-138707-06 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…
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
…ALTH PLANS
Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
IRCCourt RulingsNov 15, 2004
…tion to make any
payment of money or other property to a government
official (as defined in section 4946(c)), other than an
agreement to employ such individual for any period
after the termination of his government service if such
individual is terminating his government service within
a 90-day period.
The Senate Finan…
PLR 200226012 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsJun 28, 2002
…ock Pool (which is not a legal entity, but a group of
individuals) are disqualified persons under § 4946 with respect to Foundation.
The remainder interest in shares of Corporation that Taxpayer will transfer to
Foundation was created under a deed of gift executed on Date 1 and amended on Date
2 by Taxpayer ’ s Mother,…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable… IRCFinal Rules (FR)Jul 19, 2010
…ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCProposed Rules (FR)Proposed Apr 24, 2020
…any corporation in which it (together with certain related private foundations described in section 4946(a)(1)(H)) owns not more than 2 percent of the voting stock and not more than 2 percent in value of all outstanding shares of all classes of stock. The Treasury Department and the IRS chose not to cross-reference the…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
01.6404-4.
* * * * *
§ 301.6404-4
Suspension of interest and certain penalties when the Internal Revenue Service does not timely contact the taxpayer. (a) Suspension.
(1) In general.
(2) Treatment of amended returns and other documents.
(i) Amended returns filed on or after December 21, 2005, that show an increase in t…