IRCCourt RulingsNov 18, 2009
…rly
distributions from qualified retirement plans (10-percent additional tax) .
Respondent issued a notice of deficiency to petitioners fo r
taxable year 2004 (2004 notice) . In that notice, responden t
determined that petitioners are liable for the 10-percent additional tax on $369,690 .98 of the 2004 IRA distribution…
Notice 2013-84 — This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 23, 2013related by meaning
f otherwise nondistributable amounts. This notice also provides guidance that applies to all in-plan Roth rollovers under § 402A(c)(4). (New)
12. 409: Notice 2011–19 provides that the terms “readily tradable on an established securities market” and “readily tradable on an established market” mean employer securities th…
IRCCourt RulingsMay 19, 2011
in
2004. Leading Edge issued Forms W-2 for 2004 and filed Forms 941
for every quarter of 2004.
Weekend Warrior continued to experience working capital shortfalls, and it borrowed money from Leading Edge and Mr.
Warmoth. Between April 1 and December 31, 2004, Weekend Warrior
signed several promissory notes. On April 1, …
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
is not permitted after December 31, 2007. Notice 2007-78 modified. Section 3 of Notice 2006-79 modified and superseded.
Notice 2007-88 Notice 2007-88 This notice requests public comment on a proposal to change the process by which taxpayers obtain the consent of the Commissioner of Internal Revenue to change a method …
Notice 2016-3 — This notice provides that the Treasury and the IRS will issue guidance with respect to (1) Cycle A elections made by controlled groups and affiliated service g… IRCNoticesJan 19, 2016related by meaning
… the situations described in Rev. Rul. 2008–15. Rev. Rul. 2008–15 is hereby revoked.
ADMINISTRATIVE
Notice 2016–04 Notice 2016–04 This notice extends the due dates for the 2015 information reporting requirements, both furnishing to individuals and filing with the Internal Revenue Service, for insurers, self-insuring em…
Rev. Rul. 2004-104 — 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in … IRCRevenue RulingsNov 15, 2004
…are provided for use in determining contributions to defined benefit plans and permitted disparity.
Notice 2004-72 Notice 2004-72
2005 section 415 cost-of-living adjustments; retirement plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2005, applicable to the dollar limits on be…
Notice 2007-81 — Interest rate modifications; Pension Protection Act of 2006; targeted segments. As required by section 430(h)(2) of the Code, as added by the Pension Protectio… IRCNoticesOct 29, 2007related by meaning
…ision of insurance between members of a consolidated group. REG-105964-98 withdrawn.
EMPLOYEE PLANS
Notice 2007-81 Notice 2007-81
Interest rate modifications; Pension Protection Act of 2006; targeted segments. As required by section 430(h)(2) of the Code, as added by the Pension Protection Act of 2006, the corporate bo…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005★ strong match
…hose remedial amendment period begins on February 1st following issuance of the Cumulative List. In Notice 2004-84, 2004-2 C.B. 1030, the Service published the 2004 Cumulative List of Changes in Plan Qualification Requirements (2004 Cumulative List). The 2004 Cumulative List was used primarily by plan sponsors and prac…
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, 2007related by meaning
g email address: Notice.comments@irscounsel.treas.gov. Include the notice number (Notice 2007-100) in the subject line.
VII. EFFECT ON OTHER DOCUMENTS For service recipients and service providers who are entitled to relief under this notice, Notice 2006-100, 2006-51 I.R.B. 1109 (relating to reporting and wage withholdi…
Notice 2016-16 — Contributions to a § 401(k) or 401(m) retirement plan must not discriminate in favor of highly compensated employees. The nondiscrimination rules may be met th… IRCNoticesFeb 16, 2016related by meaning
…the annualized cost to respondents are not relevant, because each collection of information in this notice is a one-time collection. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax r…
Notice 2015-84 — The Notice provides a list of changes in plan qualification requirements to be used by plan sponsors submitting determination letter applications for plans dur… IRCNoticesDec 28, 2015related by meaning
and Notice 2011–96 (limitations on the accrual and payment of benefits under underfunded single employer defined benefit plans).
DRAFTING INFORMATION The principal author of this notice is Maxine Terry of the Office of Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this…
Notice 2009-49 — This notice provides that, if the Treasury Department (or an entity acting on its behalf) acquires preferred stock, common stock, warrants to purchase common s… IRCNoticesJun 22, 2009related by meaning
ovement and Extension Act, and the American Recovery and Reinvestment Tax Act. Notice 2006-26 superseded.
EMPLOYEE PLANS
Notice 2009-49 Notice 2009-49 This notice provides that, if the Treasury Department (or an entity acting on its behalf) acquires preferred stock, common stock, warrants to purchase common stock or ot…
Ann. 2004-43 — Alternative deficit reduction election; notice to Pension Benefit Guaranty Corporation (PBGC) and plan participants and beneficiaries. This announcement descri… IRCAnnouncementsModified May 24, 2004related by meaning
…’04 amended section 502(c)(3) of ERISA to provide that if an employer fails to provide the required notices on a timely basis to a participant or beneficiary, or to the PBGC, that employer may be liable to such participant or beneficiary or to the PBGC, in the discretion of the court, for a penalty of up to $100 a day …
IRCCourt RulingsJun 13, 2012
Petitioners elected under section 1377(a)(2) to divide the management
company's 2004 taxable year into two taxable periods--from January 1 to July 12, 2004, and from July 13 to December 31, 2004. During the January 1 to July 12,
2004, taxable period, the ESOP was the sole shareholder of the management
company. During t…
IRCCourt RulingsJun 9, 2009
…hen th
e
taxpayer acquires it .l s
Although petitioner testified he acquired
various asset s
during 2004, he also testified that the software assets he
acquired were still under development until approximately
September 2004 when aj,revision of the integrated software wa
s
completed . According, to petitioner, the Viet…
IRCRegulationsDec 30, 2016related by meaning
(c10)(3)(ii) (ii) Reasonable notice. The requirements of section 4980F and section 204(h), as amended by EGTRRA, do not apply to any plan amendment that takes effect on or after June 7, 2001 if, before April 25, 2001, notice was provided to participants and beneficiaries adversely affected by the plan amendment (and th…
Ann. 2004-52 — Correction; section 457; Rev. Rul. 2004-57. A transition rule is set forth for a plan established before June 14, 2004, that does not satisfy the requirements … IRCAnnouncementsJun 14, 2004
Announcement 2004-52
Correction Under Rev. Rul. 2004-57
Rev. Rul. 2004-57, page this Bulletin, provides that an eligible governmental plan under § 457(b) of the Internal Revenue Code must be established and maintained by an eligible employer as defined under § 457(e)(1)(A). A plan established before June 14, 2004, that…
Notice 2007-84 — Post-retirement medical and life insurance benefits; nondiscrimination; welfare benefit funds. This notice alerts taxpayers that the tax treatment of trusts pr… IRCNoticesNov 5, 2007related by meaning
from also being a listed transaction under Notice 2007-83 where the arrangement provides benefits to active employees as well as to retired employees. The IRS has previously identified certain other transactions that claim to be welfare benefit funds as listed transactions. Notice 2003-24, 2003-1 C.B. 853, describes ce…
IRCCourt RulingsJun 14, 2012
…are expenses tot ling $8,948, $13,622, and $12,865 in 2004, 2005,
and 2006, respectively.
16 -
III. Notice 2004-8, 2004-1 C.B. 333
On December 31, 2003, before petitioners filed their 2003 returns, the
Internal Revenue Servic'e (IRS) issued Notice 2004-8, 2004-1 C.B. 333, titled
Abusive Roth IRA Transactions. In Notice…
Notice 2014-77 — This notice contains the 2014 Cumulative List of Changes in Plan Qualification Requirements (2014 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 22, 2014related by meaning
…n the funding relief for single employer defined benefit pension plans under PRA 2010. (2012 C. L.) Notice 2011–96, 2011–52 I.R.B. 915, provides a sample plan amendment that plan sponsors may adopt to satisfy § 436 regarding limitations on the accrual and payment of benefits. The notice also extends both the deadline t…