IRCCourt RulingsMay 20, 1976
Rev. Rul. 69-421 (Part 2(j)(l)), 1969-2 C.B. 59, 64, sets forth respondent’s position rejecting the prior service of self-employed individuals — partners and sole proprietors — for both prior service benefits and eligibility requirements. He, therefore, concludes that the prior services of a sole proprietor cannot be c…
IRCPrivate Letter RulingsOct 21, 2016
… applies to
nonqualified plans of deferred compensation, including excess benefit plans, in various
revenue rulings. In Rev. Rul. 60-31, Situations 1 – 3, the Service held that a mere
promise to pay, not represented by notes or secured in any way, does not constitute
receipt of income by a cash basis taxpayer. Rev. Rul…
IRCCourt RulingsJan 26, 1984
…avorable tax treatment than compensation that was paid currently. Thus, under the Tax Reform Act of 1969, capital gains treatment was limited to only that portion of a lump-sum distribution attributable to contributions made before 1970. Thus, Congress itself made the tax treatment dependent upon the time of the contri…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Rul. 2014-34 — 2015 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2015 are provided for use in … IRCRevenue RulingsDec 22, 2014
INCOME TAX
Rev. Rul. 2014–29 Rev. Rul. 2014–29
Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning January 1, 2015, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for the underpayments,…
Rev. Proc. 2014-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresJan 2, 2014
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024★ strong match
…g due to resource constraints.
(11) Any frivolous issue, as that term is defined in section 6.10 of Rev. Proc. 2025-1, this Bulletin.
(12) A request that does not comply with the provisions of Rev. Proc. 2025-1, this Bulletin.
SECTION 4. AREAS IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT ORDINARILY BE ISSUED
.01 …
Rev. Proc. 2008-61 — This procedure provides areas affected by section 409A of the Code in which rulings will not be issued. Rev. Proc. 2008-3 modified and amplified. IRCRevenue ProceduresOct 20, 2008related by meaning
… experience with the private letter ruling program, the Service has determined that section 5.08 of Rev. Proc. 2008-3 unnecessarily restricts the ability of the Service to issue private letter rulings under Rev. Proc. 2008-1, 2008-1 I.R.B. 1 and Rev. Proc. 2008-4, 2008-1 I.R.B. 121. For example, the existing no-rule po…
Rev. Rul. 2004-67 — Group or pooled trusts; participation; tax-exempt status, model language. This ruling provides that a governmental section 457(b) plan may invest in a second t… IRCRevenue RulingsJul 12, 2004related by meaning
…mination letter issued to it prior to July 12, 2004, regarding eligibility of its group trust under Rev. Rul. 81-100 will not lose its right to rely on its determination letter merely because it adopts Model Amendment 1 set forth above in this revenue ruling on a word-for-word basis (or adopts an amendment that is subs…
PLR 200202027 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 11, 2002related by meaning
…orary or final regulations are inconsistent with any
conclusion in the ruling. See section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46. However, when the criteria in section 12.05 of Rev. Proc. 2001-1 are satisfied, a ruling
is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely…
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
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
… under a life or endowment insurance contract held by an employees’ trust qualified under § 401(a). Rev. Rul. 66-110, 1966-1 C.B. 12, provided that the current published premium rates charged by an insurer for individual 1-year term life insurance available to all standard risks may be used for determining the cost of …
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the … IRCRevenue ProceduresJan 4, 2016
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2015-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the … IRCRevenue ProceduresJan 2, 2015
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
IRCPrivate Letter RulingsJul 19, 2002related by meaning
…orary or final regulations are inconsistent with any
conclusion in the ruling. See section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46. However, when the criteria in section 12.05 of Rev. Proc. 2001-1 are satisfied, a ruling
is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely…
Rev. Proc. 2013-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresJan 2, 2013
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …