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))…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCProposed Rules (FR)Proposed Apr 24, 2020
…es over total support.
See
§ 1.170A-9(f) (definition of section 170(b)(1)(A)(vi) organization); § 1.509(a)-3 (publicly supported organizations). Section 512(a)(6) potentially impacts two aspects of the public support test. First, section 512(a)(6) potentially impacts the calculation of total support under section 509(d…
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 …
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
Notice 2005-1 — This notice provides general and transitional guidance relating to new section 409A of the Code, added as part of the American Jobs Creation Act of 2004. Secti… IRCNoticesJan 10, 2005related by meaning
its case to the U.S. competent authority under Article 28(4)(b) or seek a bilateral mutual agreement between the U.S. and Swiss competent authorities. Verification. The status of any Swiss pension or other retirement arrangement claiming benefits under Article 10(3) is subject to verification by the U.S. tax authoritie…
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…
IRCRegulationsJul 12, 2016
(b)(2)(v) (v) Section 509(a)(2) (relating to organizations publicly supported by admissions, sales, etc.), or
(b)(2)(vi) (vi) Section 509(a)(3) (relating to organizations supporting public charities), except that for purposes of this paragraph (b)(2), section 509(a)(3) shall be applied without regard to the last senten…
IRCCourt RulingsMar 14, 2005
…. As of
that date, petitioner’s investment in the policy was $14,565, the
accumulated value was $23,509, the outstanding loans plus accrued
interest payable was $23,125, and the cash surrender value
- 5 -
totaled $384 (i.e., $23,509 less $23,125), which petitioner
received in cash.
For the taxable year 2001, Pacific Li…
IRCPrivate Letter RulingsApr 2, 1999related by meaning
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
December 17, 1998
CC:DOM:FS:CORP
Number: 199913003
Release Date: 4/2/1999
Number:TL - N - 748-98
UILC: 1502.90-01
404.15-00
INTERNAL REVENUE SERVICE NATIONA L OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR ASSOCIATE DISTRICT COUNSEL
FROM: DEBORAH A.…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
80 FR 57709 — Reliance Standards for Making Good Faith Determinations IRCFinal Rules (FR)Sep 25, 2015
…h has not received a ruling or determination letter that it is an organization described in section 509(a)(1), (a)(2), or (a)(3) or in section 4942 (j)(3), will be treated as a distribution made to an organization described in section 509(a)(1), (a)(2), or (a)(3) (other than an organization described in section 4942(g)…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
ERISA § 3002(e) (29 U.S.C. § 1202) — Procedures with respect to continued compliance with Internal Revenue requirements relating to participation, vesting, and funding standards ERISACode / StatuteJan 5, 2015related by meaning
(e) (e) Consultative requirements respecting promulgation of proposed or final regulations The Secretary of the Treasury shall consult with the Pension Benefit Guaranty Corporation with respect to any proposed or final regulation authorized by subpart C of part I of subchapter D of chapter 1 of title 26, or by sections…
IRCCourt RulingsFeb 29, 2012related by meaning
urd result. We agree. ,It is a well-established canon of statutory .
interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep.
Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v.
Keystone Consol…
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-7 Rev. Rul. 2006-7
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2006.
T.D. 9238 T.D. 9238
Temporary and proposed regul…
IRCCourt RulingsMar 9, 2011related by meaning
ds of thousands of dollars
in DISC commissions each year from a well-established business,
and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount.
-28IV. Section 6662(a) Penalty
Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…