Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 677 (not yet in the library — opens the official source)
84 documents · 0.33sAllIRCERISAPBGCJoint Board
  1. PLR 200518008 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations
    IRCPrivate Letter RulingsMay 6, 2005
    uting the taxable income or credits against the tax of an individual). Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose inco me without the approval or consent of any adverse party is, or in the discretion of t he grantor or an adverse party or both m…
  2. PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.)
    IRCPrivate Letter RulingsJun 25, 1999
    … account under chapter 1 in computing taxable income or credits against tax of an individual). IRC §677(a)(2) provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the gr antor or a nonadverse part…
  3. PLR 200321002 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations
    IRCPrivate Letter RulingsMay 23, 2003
    …ccount under chapter 1 in computing taxable income or credits against tax of an individual. Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the grantor or a nona…
  4. PLR 199912002 — Year of Deduction
    IRCPrivate Letter RulingsMar 26, 1999
    … that the term "grantor" as used in the regulations under subpart E includes a corporation. Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the grantor or a nona…
  5. PLR 199910002 — Year of Deduction
    IRCPrivate Letter RulingsMar 12, 1999
    … that the term "grantor" as used in the regulations under subpart E includes a corporation. Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the grantor or a nona…
  6. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  7. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …Conceded At issue Meals and entertainment $346 $346 --- $346 Travel 401 401 --- 401 Office expenses 677 677 --- 677 Advertising 289 289 --- 289 i. Meals and Entertainment For the reasons explained supra part II(A)(2)(i), petitioners failed to satisfy the substantiation requirements of section 274(d). Accordingly, they …
  8. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    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…
  9. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
  10. PLR 199910006 — Deferred Compensation
    IRCPrivate Letter RulingsMar 12, 1999
    …count under chapter 1 in computing taxable income or credits against tax of an individual). Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the grantor or a nona…
  11. PLR 199906008 — Deferred Compensation
    IRCPrivate Letter RulingsFeb 12, 1999
    …pter 1 of the Code in computing taxable income or credits against the tax of an individual. Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income, without the approval or consent of any adverse party, is or, in the discretion of the grantor or a non…
  12. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  13. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    atement for any taxable year, there shall be added to the tax an amount equal to 20% of the amount of such understatement." The penalty applies to any deficiency which is attributable to any listed transaction or any reportable transaction if a significant purpose of the transaction is the avoidance or evasion - 41 - o…
  14. 20 C.F.R. § 901.12(f)(1)(iii) — Eligibility for enrollment.
    Joint BoardRegulationsOct 18, 2016related by meaning
    (f)(1)(iii) (iii) Willfully failing to make a Federal tax return in violation of the revenue laws of the United States, or evading, attempting to evade, or participating in any way in evading or attempting to evade any federal tax or payment thereof, knowingly counseling or suggesting to a client or prospective client …
  15. Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex…
    IRCNoticesNov 13, 2007related by meaning
    g whether an estate making the section 6166 election will be required to provide security. TAX CONVENTIONS Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
  16. Treas. Reg. § 54.4975-14(c) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (c) (c) Method of election. A person shall make the election referred to in this section by filing the form issued for such purpose by the Internal Revenue Service, including therein the information required by such form and the instructions issued with respect thereto, and by paying the tax which the taxpayer indicate…
  17. PLR 200703012 — Year of Inclusion in Gross Income
    IRCPrivate Letter RulingsJan 19, 2007
    …ccount under chapter 1 in computing taxable income or credits against tax of an individual. Section 677(a)(2) of the Code provides that the grantor shall be treated as the owner of any portion of a trust whose income without the approval or consent of any adverse party is, or, in the discretion of the grantor or a nona…
  18. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    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…
  19. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025related by meaning
    cluding false returns), (10) failing to file returns, and (11) dealing in 12 The revenue agent (RA) determined to assert the fraud penalty against Mr. Hutcheson. Before respondent issued the Notice of Deficiency, the RA’s immediate supervisor approved the RA’s determination in writing as required by section 6751(b). Se…
  20. 75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans
    ERISAProposed Rules (FR)Proposed Aug 30, 2010related by meaning
    s assessed by the Treasury and Labor Departments in connection with prior prohibited transactions —The current version of § 2570.35(a)(14)(v) requires ( printed page 53177) an applicant to disclose whether any excise taxes due under sections 4975(a) and (b) of the Code by reason of a consummated exemption transaction h…