PLR 202417010 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsApr 26, 2024
t cause
Taxpayer to fail to qualify as an 81-100 group trust within the meaning of Rev. Rul.
2011-1.
LAW AND ANALYSIS
Rev. Rul. 81-100, as modified,
1 provides that certain retiree benefit plans and other
arrangements are permitted to pool their assets for investment purposes in an “81-100
group trust” if certain speci…
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★ strong match
…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. 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
…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. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresModified Jan 2, 2013related by meaning
…rators or sponsors of a defined benefit plan to obtain approval for a change in funding method, see Rev. Proc. 2000-41, 2000-2 C.B. 371. (7) For requests for the return to the employer of certain nondeductible contributions, see Rev. Proc. 90-49, 1990-2 C.B. 620 (as modified by Rev. Proc. 2013-8).
(8) For requests for …
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 …
Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014★ strong match
… of that state, and the term “marriage” does not include such formal relationships. The holdings of Rev. Rul. 2013–17 apply for all Federal tax purposes, including for purposes of the Federal tax rules that apply to qualified retirement plans under section 401(a). The ruling provides that the holdings will be applied p…
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. 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. 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 …
Rev. Proc. 2008-67 — This document sets forth the procedure by which the sponsor of a multiemployer pension plan may request and obtain approval of an extension of an amortization … IRCRevenue ProceduresSuperseded Dec 1, 2008related by meaning
or write for guidance to the following address:
Internal Revenue Service
Commissioner, TE/GE
Attention: SE:T:EP:RA:T:A2
1111 Constitution Avenue, N.W. Washington, D.C. 20224 In appropriate instances, pre-submission conferences may be afforded in addition to conferences available under Rev. Proc. 2008-8.
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 …
Rev. Proc. 2012-6 — 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, 2012
…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. 2011-6 — 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, 2011
.02 A request for a determination letter on the status of a group trust as described in Rev. Rul. 81-100 is made by submitting a written request demonstrating how the group trust satisfies the five criteria listed in Rev. Rul. 81-100, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends t…
IRCCourt RulingsAug 6, 1996related by meaning
… are, by contract, mechanical and predictable.
Whether the private letter rulings, plus the TAM and Rev. Rul.
76-28, rise to the level of "longstanding administrative
practice" is, to say the least, problematical, but in any event,
as the Supreme Court has stated in Dixon v. United States
, 381
- 29 -
U.S. 68, 73 (1965…
PLR 202524006 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsJun 13, 2025
…“group t rust retiree benefit plans,” are qualified retirement plans under § 401(a) of the Internal Revenue Code (Code); governmental retiree benefit
plans under § 401(a)(24); certain custodial accounts under § 403(b)(7); retirement
income accounts under § 403(b)(9 ); IRAs that are exempt under § 408(e); eligible
gover…
IRCPrivate Letter RulingsNov 13, 2015
ed in any way, does not constitute
PLR-T-102477-15
8
receipt of income by a cash basis taxpayer. Rev. Rul. 60-31, 1960-1 C.B. 174, as
modified by Rev. Rul. 64-279, 1964-2 C.B. 121, and Rev. Rul. 70-435, 1970-2 C.B. 100;
see also Rev. Rul. 69-650, 1969-2 C.B. 106, Rev. Rul. 69-649, 1969-2 C.B. 1 06; and
Rev.
Rul. 71-419…
90 FR 28004 — Removal of Interpretive Bulletins Relating to the Employee Retirement Income Security Act of 1974 ERISAFinal Rules (FR)Jul 1, 2025related by meaning
…75-6”).
Back to Citation 7.
41 FR 3289 (Jan. 22, 1976).
Back to Citation
8.
43 FR 47713 (Oct. 17, 1978). Congress subsequently ratified Reorganization Plan No. 4 in 1984. See Sec. 1, Public Law 98-532, 98 Stat. 2705 (Oct. 19, 1984).
Back to Citation
[FR Doc. 2025-11613 Filed 6-30-25; 8:45 am]
BILLING CODE 4510-29-P