IRCCourt RulingsApr 20, 2017
to "provide[] for a self-certification procedure" and to modify Rev. Proc.
2003-16, supra, "by providing that the Internal Revenue Service may grant a waiver during an examination". But these two purposes are accomplished in
different ways. Whereas section 3 of Rev. Proc. 2016-47, 2016-37 I.R.B. at 347,
provides for a …
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024★ strong match
…ons and adds new provisions for the retroactive adoption of safe harbor status for those plans. (h) Rev. Proc. 2021-30, 2021-31 IRB 172, sets forth the procedures for correcting qualification and other eligible failures under the Employee Plans Compliance Resolution System (EPCRS). This includes the Voluntary Correctio…
Rev. Proc. 2014-8 — User fees for employee plans and exempt organizations. Current guidance for complying with the user fee program of the Service as it pertains to requests for l… IRCRevenue ProceduresJan 2, 2014
istrative scrutiny determination
Rev. Proc. 93–41
Adoption agreement
Rev. Procs. 2011–49, 2013–22
Advisory letter
Rev. Procs. 2011–49, 2013–22, 2014–6 Basic plan document
Rev. Procs. 2011–49, 2013–22
Determination letter
Rev. Procs. 2014–6, 2014–9
Dual-purpose IRA
Rev. Procs. 98–59, 2010–48
Group exemption letter
Rev. …
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★ strong match
gement described in Rev. Proc. 92-64, the tax consequences of the use of a trust, other than the model trust described in that revenue procedure.
(40) Sections 671 to 679.—Grantors and Others Treated as Substantial Owners—Whether an Indian tribe (as defined in 25 U.S.C. § 2703(5)) that establishes a trust to receive an…
Rev. Proc. 2010-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 4, 2010
d defined benefit plans are different than those that apply to individually designed plans. See Rev. Proc. 2005-16 and Rev. Proc. 2007-44 for details. SECTION 4. ON WHAT ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?
TE/GE
.01 Other procedures for obtaining rulings, determination letters, opinion…
Rev. Proc. 2009-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 5, 2009
Rev. Proc. 2005-16 and Rev. Proc. 2007-44 for details.
SECTION 4. ON WHAT ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?
TE/GE .01 Other procedures for obtaining rulings, determination letters, opinion letters, etc., on matters within the jurisdiction of the Commissioner, TE/GE are contained in …
Rev. Proc. 2007-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 2, 2007
Rev. Proc. 2005-16 and Rev. Proc. 2005-66 for details.
SECTION 4. ON WHAT ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?
TE/GE .01 Other procedures for obtaining rulings, determination letters, opinion letters, etc., on matters within the jurisdiction of the Commissioner, TE/GE are contained in …
Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2006
Rev. Proc. 2005-16 and Rev. Proc. 2005-66 for details.
SECTION 4. ON WHAT ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?
TE/GE .01 Other procedures for obtaining rulings, determination letters, opinion letters, etc., on matters within the jurisdiction of the Commissioner, TE/GE are contained in …
Rev. Proc. 2004-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 5, 2004
… etc., on matters within the jurisdiction of the Commissioner, TE/GE are contained in the following revenue procedures: (1) Employee Plans Technical (EP Technical) letter rulings, information letters, etc.: See Rev. Proc. 2004-4, page , this Bulletin.
(2) M&P plans: See Rev. Proc. 2000-20, 2000-1 C.B. 553, as modified …
IRCCourt RulingsSep 24, 2007
on the joint return . Therefore, Rev . Proc . 2003-61,
sec . 4 .02, does not apply .
Rev . Proc . 2003-61, sec . 4 .03, 2003-2 C .B . at 298, provides a nonexclusive list of factors respondent considers in evaluating
whether it would be inequitable to hold petitioner liable for all
or part of an unpaid income tax liabi…
IRCCourt RulingsAug 16, 2005
ibed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296,
8
to
- 18 -
8
(...continued)
1 C.B. 447, and is effective either for requests for relief filed on or after Nov. 1, 2003, or for requests for which no
preliminary determination letter was issued as of Nov. 1, 2003.
In the present case, the request for relief was st…
Rev. Proc. 2008-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 7, 2008
d defined benefit plans are different than those that apply to individually designed plans. See Rev. Proc. 2005-16 and Rev. Proc. 2007-44 for details. SECTION 4. ON WHAT ISSUES MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?
TE/GE
.01 Other procedures for obtaining rulings, determination letters, opinion…
Rev. Proc. 2005-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2005
… etc., on matters within the jurisdiction of the Commissioner, TE/GE are contained in the following revenue procedures:
(1) Employee Plans Technical (EP Technical) letter rulings, information letters, etc.: See Rev. Proc. 2005-4, page , this Bulletin.
(2) M&P plans: See Rev. Proc. 2000-20, 2000-1 C.B. 553, as modified …
IRCPrivate Letter RulingsSep 12, 2003related by meaning
…ssues addressed in this
ruling have not yet been adopted. Therefore, this ruling may be modified or revoked if
the adopted temporary or final regulations are inconsistent with any conclusions in the
ruling. See section 12.04 of Rev. Proc. 2003-1, 2003-1 I.R.B. 1, 44. However, when the
criteria in section 12.06 of Rev. …
IRCPrivate Letter RulingsNov 3, 2006related by meaning
006-1, 2006-1 I.R.B. 1, 49. However, when the
PLR-158734-05
4
criteria in section 11.06 of Rev. Proc. 2006-1 are satisfied, a ruling is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely,
Robert D. Patchell
Chief, Qualified Plans Branch 2
Office of the Associate Chief Counsel
(Tax …
Rev. Proc. 2022-40 — Rev. Proc. 2022-40 modifies Rev. Proc. 2016-37, 2016-29 IRB 136, which, in part, provides the circumstances under which a plan sponsor may submit a determinati… IRCRevenue ProceduresNov 21, 2022
ev. Proc. 2017-41, 2017-29 IRB 92, Rev. Proc. 2019-20, 2019-20 IRB 1182, Rev. Proc. 2020-40, 2020-38 IRB 575, and Rev. Proc. 2021-38, 2021-38 IRB 425. 2 For purposes of this revenue procedure, references to Rev. Proc. 2019-39 are to Rev. Proc. 2019-39, as modified by Notice 2020-35, 2020-25 IRB 948, Rev. Proc. 2020-40,…
Rev. Proc. 2013-12 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresJan 22, 2013related by meaning
…ng the deduction and capitalization of expenditures relating to tangible property. These amendments revise the general asset account regulations to provide the time and manner of making a general asset account election.
Announcement 2013-8 Announcement 2013-8
This document solicits recommendations and/or comments regar…
Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2022
…mitted with respect to cycles prior to the third six-year remedial amendment cycle are contained in Rev. Proc. 2015-36. (2) The procedures for obtaining opinion letters for pre-approved plans submitted with respect to the third six-year remedial amendment cycle (and subsequent cycles) are set forth in Rev. Proc. 2017-4…
Rev. Proc. 2005-66 — Qualification; determination letters; staggered remedial amendment periods. This procedure contains the Service’s procedures for issuing determination letters … IRCRevenue ProceduresSuperseded Sep 12, 2005related by meaning
…y 1, 2011 and ends on January 31, 2012 for the next six-year cycle. Sponsor S’s application will be reviewed using the 2004 Cumulative List.
SECTION 21. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2000-27, 2000-1 C.B. 1272, is modified and superseded. Notice 2001-42, Rev. Proc. 2005-6, Rev. Proc. 2005-16 and Announcement 2005…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018related by meaning
compensation” pursuant to Rev. Rul. 2002–27, 2002–1 C.B. 925. For rules relating to a failure to adopt a Good Faith Amendment, see Rev. Proc. 2013–12. (B) “Interim Amendment” means an amendment with respect to a disqualifying provision that results in the failure of the plan to satisfy the qualification requirements of…