IRCPrivate Letter RulingsJun 13, 2014
…e)(2), a result
inconsistent with general income tax principles.
F ourth, the provisions of section 264(a) disallowing deductions on indebtedness to purchase or carry certain annuities further support our conclusion that the doctrine of
constructive receipt does not apply to annuities. In fact, section 264(a)(3) genera…
IRCPrivate Letter RulingsMay 31, 2013
…contracts as not
resulting in a loss of “grandfathered” status for purposes of sections 72, 101(f), 264,
7702, and 7702A of the Internal Revenue Code and as not requiring retesting or the
beginning of a new test period under sections 264([d])(1), 7702(f)(7)(B) - (E), and
7702A(c) of the Code.” Rev. Proc. 92-57.
PLR - 1…
ERISACode / StatuteJan 8, 2008related by meaning
(b) (b) Omitted.
PBGCCode / StatuteJan 6, 2017related by meaning
(a) (a) In general Any person who is with respect to a single-employer plan a fiduciary, contributing sponsor, member of a contributing sponsor's controlled group, participant, or beneficiary, and is adversely affected by an act or practice of any party (other than the corporation) in violation of any provision of sect…
ERISACode / StatuteJan 4, 1995related by meaning
(6) (6) an individual retirement account or annuity described in section 408 of title 26, or a retirement bond described in section 409 of title 26 (as effective for obligations issued before January 1, 1984);
(7) (7) an excess benefit plan; or
(8) (8) any plan, fund or program under which an employer, all of whose sto…
PLR 200742010 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsOct 19, 2007
…(e)(2), a result
inconsistent with general income tax principles.
Fourth, the provisions of section 264(a) disallowing deductions on indebtedness to
purchase or carry certain annuities further su pport our conclusion that the doctrine of
constructive receipt does not apply to annuities. In fact, section 264(a)(3) gener…
80 FR 72006 — Savings Arrangements Established by States for Non-Governmental Employees ERISAProposed Rules (FR)Proposed Nov 18, 2015related by meaning
…(S.B. 1234) (West); Oregon 2015 Session Laws, Ch. 557 (H.B. 2960) (June 2015).
Back to Citation
5. ERISA includes several express exemptions in section 4(b) from coverage under Title I, for example, for pension plans established or maintained by governmental entities or churches for their employees, certain foreign pl…
80 FR 55249 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Sep 15, 2015
…)
On or after
Before
i1
i2
i3
n1
n2
* * * * * * *
264
10-1-15
11-1-15
1.25
4.00
4.00
4.00
7
8
3. In appendix C to part 4022, Rate Set 264, as set forth below, is added to the table.
Appendix C to Part 4022—Lump Sum Interest Rates for Private-Sector Payments
* * * * *
Ra…
IRCCourt RulingsJun 4, 1984related by meaning
nd holding of employer securities and employer real property by certain plans. Section 408, ERISA, sets forth exemptions from prohibited transactions. Violations of the labor provisions contained in ERISA may result in any number of sanctions against the fiduciary. For example, under section 409(a), ERISA, a fiduciary …
IRCPrivate Letter RulingsJul 31, 2009
… (or the employer) is
directly or indirectly a beneficiary under the policy within the meaning of § 264(a). This
is because a fund’s qualified direct cost does not include amounts that would not have
been deductible if the employer had provided the benefit directly. In situations involving
premiums paid by a fund for c…
81 FR 59464 — Savings Arrangements Established by States for Non-Governmental Employees ERISAFinal Rules (FR)Aug 30, 2016related by meaning
…., 463 U.S. 85, 96-97 (1983) (footnote omitted). In various decisions, the Court has concluded that ERISA preempts state laws that: (1) mandate employee benefit structures or their administration; (2) provide alternative enforcement mechanisms; or (3) bind employers or plan fiduciaries to particular choices or preclude…
Rev. Proc. 2006-3 — 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, 2006
…er or the taxpayer’s spouse or dependent, or is related directly to such medical care.
(22)
Section 264(b).—Certain Amounts Paid in Connection with Insurance Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 years from the date on which the contract is purchase…
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, 2005
…er or the taxpayer’s spouse or dependent, or is related directly to such medical care.
(20)
Section 264(b).—Certain Amounts Paid in Connection with Insurance Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 years from the date on which the contract is purchase…
ERISACode / StatuteJan 6, 2025related by meaning
(44)(A)(i)(I) (I) the plan meets any requirement applicable under this chapter or title 26 to a plan described in section 401(a) of title 26, a plan that consists of annuity contracts described in section 403(b) of title 26, or to a plan that consists of individual retirement accounts described in section 408 of title …
IRCCourt RulingsSep 25, 1996
…ip taxable income of
$840,069 for 1987. This consisted of $637,316, one-fourth of the
- 45 -
$2,549,264 deferred income that it was allocating over 4 years,
plus $231,253 in accrued interest payable from MPC, less
$28,500--a management fee expense to BBPA.
On its partnership return for 1988, MIT 82 reported
partnership…
86 FR 73976 — Revision of Annual Information Return/Reports ERISAFinal Rules (FR)Dec 29, 2021related by meaning
…an, are matters that generally are subject to the fiduciary responsibility provisions of Title I of ERISA”.); Information Letter to Diana Ceresi (Feb. 2, 1998) (“when the selection of a health care provider involves the disposition of employee benefit plan assets, such selection is an exercise of authority or control w…
IRCCourt RulingsMar 26, 1979
…rms. Nor has respondent indicated any statutory language, either in subsection 72(e)(1)(B), section 264, or any other section, from which, a distinction can be drawn between policy loans against employee annuity contracts and other policy loans. Yet, we are convinced that Congress considered policy loans to be a valid …
IRCPrivate Letter RulingsDec 20, 2013
…provided in
section 1011 for determining the loss from the sale or disposition of property.
Section 264 prevents the current deduction of premium s otherwise allowable as
a deduction under sections 162 and 212. Section 1.263(a) - 4(d)(2) provides that a life
insurance policy is a financial interest that must be capital…
IRCPrivate Letter RulingsApr 4, 2008
…e that such contract was issued, entered into, or
purchased for purposes of §§ 72, 101( f), 101(j), 264, 7702, or 7702A, or
(ii) will require retesting or the start of a new test period for such contract under
§§ 264(d)(1), 7702(f)(7)(B)-(E), or 7702A(c).
15
For purposes of (2)(i) and (ii) above, as each endorsed contr…
IRCCourt RulingsMay 15, 1978related by meaning
… section 3002(c) of the Employee Retirement Income Security Act of 1974 (hereinafter referred to as ERISA) which provides: Regulations prescribed by the Secretary of Treasury under sections 410(a), 411, and 412 of the Internal Revenue Code of 1954 (relating to minimum participation standards, minimum vesting standards,…