IRCCourt RulingsMay 19, 2011related by meaning
treated as a gift, dividend,
contribution of capital, payment of compensation, or other
payment depending on the substance of the transaction. Section 7872 applies to a transaction that is a loan subject to a belowmarket interest rate and is described in one of several
enumerated categories. Sec. 7872(c) (1), (e) (1), …
T.D. 9169 — Final regulations provide guidance for certain retirement plans containing cash or deferred arrangements under section 401(k) of the Code, and provide for matc… IRCTreasury DecisionsJan 31, 2005related by meaning
401(k) of the Code, and provide for matching contributions or employee contributions under section 401(m).
ADMINISTRATIVE
Notice 2005-3 Notice 2005-3 Presidentially declared disasters. This notice advises taxpayers that Rev. Proc. 2004-13, 2004-4 I.R.B. 335, will be modified retroactively to provide additional tax reli…
T.D. 9769 — These final regulations provide guidance on distributions from designated Roth accounts. The guidance removes a rule that had required a direct rollover to an … IRCTreasury DecisionsJun 6, 2016related by meaning
INCOME TAX
Rev. Rul. 2016–13 Rev. Rul. 2016–13
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for June 2016.
Notice 2016–31 Notice 2016–31
Beginning of Constr…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field.
Discussion with the taxpayer
.03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field.
Discussion with the taxpayer
.03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
lect to receive a cash out of all remaining installments. Participant M elects to receive a distribution in 10 annual installments commencing in 2004. (ii) Conclusion. M’s total account balance, representing the total of the amounts deferred under the plan, is considered made available and is includible in M’s gross in…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016related by meaning
tnership, or
3. the beneficial interest of such trust or estate, is owned directly or indirectly, or held by persons described in A, B, C, D, or E;
H. An employee, officer, director (or an individual having powers or responsibilities similar to those of officers or directors), or a 10% or more shareholder directly or i…
IRCPrivate Letter RulingsNov 14, 2008related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Third Party Communication: None
Date of Communication: Not Applicable
Number: 200846021
Release Date: 11/14/2008
Index (UIL) No.: 404.10-00, 461.00-00, 105.00-00 July 23, 2008
CASE - MIS No.: TAM - 100141-08
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------------------…
T.D. 9783 — These final regulations change the regulations regarding the minimum present value requirements for defined benefit plan distributions to permit plans to simpl… IRCTreasury DecisionsSep 26, 2016related by meaning
t value requirements of section 417(e)(3) because it is treated as a separate optional form of benefit under paragraph (d)(7)(iii)(A) of this section. (v) If, instead, Plan B’s terms had provided for a single-sum payment equal to the present value of the participant’s employee-provided accrued benefit as determined und…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
INCOME TAX
Rev. Rul. 2013–26 Rev. Rul. 2013–26
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2013.
EMPLOYEE PLANS
T.D. 9641 T.D. 9641
These final…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
(B) Deemed satisfaction of timing requirement. The timing requirement of this paragraph (b)(3)(iii) is satisfied if at least 30 days (and no more than 90 days) before the beginning of each plan year, the notice is given to each employee covered under the automatic contribution arrangement for the plan year. In the case…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …