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85 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 84 FR 26605 — Exception for Interests Held by Foreign Pension Funds
    IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
    timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in the Federal Register . Drafting Information The principal authors of these proposed regulations are Joshua Rabon, formerly with the Office of Associate Chief Counsel (Intern…
  2. 29 C.F.R. § 2570.95 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(5) civil penalty proceedings, the following shall apply in lieu of 29 CFR 18.9.
  3. Joint BoardRegulationsDec 30, 2016related by meaning
    (d)(4)(iii) (iii) Denials. If a motion for a protective order is denied in whole or in part, the Administrative Law Judge may, on such terms or conditions as the Administrative Law Judge deems just, order any party or person to comply with, or respond in accordance with, the procedure involved. (d)(4)(iv) (iv) Public i…
  4. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    )(i), as contained in 26 CFR part 1, revised as of April 1, 2024. Douglas W. O'Donnell, Deputy Commissioner. Approved: April 2, 2024. Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  PLR 200923001 (February 26, 2009). Back to Citation 2.   See also STAFF OF THE JOINT COMM. ON TAX'…
  5. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    licability, see §§ 1.6033-5(f), 53.4965-9(b) and (c), 53.6071-1(h), 54.6011-1(d), 301.6011(g)-1(j) and 301.6033-5(b). FOR FURTHER INFORMATION CONTACT: For questions concerning these regulations, contact Benjamin Akins at (202) 622-1124 or Michael Blumenfeld at (202) 622-6070. For questions specifically relating to qual…
  6. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 MAY 13 2014 Uniform Issue List: 408.03-00, 2501.00-00, 4973.00-00, 4974.00-00 * * * * * * * * * Legend: Taxpayer A = * * * Decedent 8 = * * * Decedent c = * * * Charity D = * * * Trust = * * * Financia…
  7. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004
    …, Inc. v. Commissioner , 108 T.C. 100, 102-103 (1997); F.W. Woolworth Co. v. Commissioner , 54 T.C. 1233, 1265-1266 (1970). Nevertheless, we find that respondent’s position in the proposed regulation makes more sense than respondent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissione…
  8. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    or lack of jurisdiction. Appropriate orders will be issued. Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
  9. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …2); Zinniel v. Commissioner , 89 T.C. 357, 369 (1987); F.W. Woolworth Co. v. Commissioner , 54 T.C. 1233, 1265-1266 (1970). Nonetheless, we find that respondent's position in the proposed regulation makes more sense than the respondent's litigating position in this case. Respondent's litigating position is logically in…
  10. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
  11. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
  12. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997
    …eight than a position advanced by respondent on brief. F.W. Woolworth Co. v. Commissioner , 54 T.C. 1233, 1265-1266 (1970). Our use of the word "offset" does not indicate any reliance on the proposed regulation. During tax year 1992, the Bank of New Hampshire foreclosed on the timeshares. Petitioners received $15,000 i…
  13. T.C. Summary Opinion 2016-52 — Bruce W. Peterson & Lisa A. Peterson v. Commissioner
    IRCCourt RulingsSep 1, 2016
    …efore signing and filing them. Magill v. Commissioner, 70 T.C. 465, 479-480 (1978), aff d, 651 F.2d 1233 (6th Cir. 1981). "Reliance on a tax return preparer cannot absolve a taxpayer from the responsibility to file an accurate return." Devy v. Commissioner, T.C. Memo. 2015-110, at *4 (citing Metra Chem Corp. v. Commiss…
  14. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub…
  15. PLR 200944051 — Initial Tax
    IRCPrivate Letter RulingsOct 30, 2009
    … a dummy corporation when it ceases to have business activity or purpose. See Owens v. CIR, 568 F2d 1233 (6th Cir.1977) (purported sale of S corporation stock treated as indire ct distribution of assets to shareholders where corporation no longer served any business purpose). Wh ether or not corporation can be disregar…
  16. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
    nt participated in their development. List of Subjects in 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301—PROCEDURE AND…
  17. Treas. Reg. § 1.72-2(ii)(3) — Applicability of section.
    IRCRegulationsJul 26, 2016related by meaning
    (ii)(3) (3)
  18. 29 C.F.R. § 2570.34(f)(11)(i)(E) — Information to be included in every exemption application.
    ERISARegulationsApr 8, 2024related by meaning
    (f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
  19. 82 T.C. 686; 82 T.C. No. 53 — Holswade v. Commissioner
    IRCCourt RulingsApr 26, 1984
    …. See Magill v. Commissioner, 70 T.C. 465, 478-479 (1978), affd. without published opinion 651 F.2d 1233 (6th Cir. 1981). We have chosen, in the instant case, to adhere to the parties’ view of the parameters of the controversy. See Estate of Fusz v. Commissioner, 46 T.C. 214, 215 n. 2 (1966).
  20. Treas. Reg. § 54.4975-14(c) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (c) (c) Method of election. A person shall make the election referred to in this section by filing the form issued for such purpose by the Internal Revenue Service, including therein the information required by such form and the instructions issued with respect thereto, and by paying the tax which the taxpayer indicate…