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80 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    e relaxed transfer pricing rules of section 925(a)(1) and (2) were used instead of the normal section 482 rules, then the lower the profit margin on a particular export transaction, the lower the effective marginal tax rate for that transaction (because as the profit margin decreased, the amount of taxable income assig…
  2. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
  3. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005
    T.C. Memo. 2005-192 UNITED STATES TAX COURT ARTHUR F. MILLARD, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3713-04. Filed August 8, 2005. Arthur F. Millard, pro se. Travis T. Vance III , for respondent. MEMORANDUM OPINION WELLS, Judge : Respondent determined a deficiency of $2,764 in petition…
  4. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    use these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy of the Small Busin…
  5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005
    …ent is a neutral factor in determining whether TLC is the employer of each driver-employee." Id. at 192-193. That TLC may have paid TLC's payroll obligation with moneys that it received from its trucking company clients did not evidence to the Court in Transport Labor I that TLC was or was not the employer of each driv…
  6. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971
    … Tool & Machine Corporation, 27 T.C. 372 (1956); 555, Inc., 15 T.C. 671 (1950), affirmed per curiam 192 F. 2d 575 (C.A. 8, 1951). For purposes of determining whether contributions are deductible, it has been held that a trust exists when, and only when, the trust has a res. West Virginia Steel Corporation, 34 T.C. 851 …
  7. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    … prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943); Midtown Catering Co., 13 T. C. 92 (1949). In the Block case we added to this view the beli…
  8. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    acted in good faith with respect to such portion. ” Unlike the reasonable cause and good faith exception found in section 6664(c), Congress placed the adequate disclosure exception in section 6662(d), with no text indicating that it was meant to apply to multiple section 6662 penalties. The reason for t his is apparent…
  9. I.R.C. § 6652(c)(2)(C) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
  10. 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.
  11. 89 FR 58886 — Required Minimum Distributions
    IRCFinal Rules (FR)Jul 19, 2024related by meaning
    ensions Railroad retirement Reporting and recordkeeping requirements Social security Unemployment compensation 26 CFR Part 54 Excise taxes Health care Pensions Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, the Treasury Department and the IRS amend 26 CFR parts 1, 31, an…
  12. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …2,907 Business Operations Specialist 150 74.00 11,100 Lawyer 2 138.68 277 Chief Executive Officer 1 192.44 192 Total per respondent 2,508 221,029 Table 3B—Total High-End Estimated One-Time Cost and Hour Burden for Internet-Based Self-Service Tool for All Health Insurance Issuers and TPAs Number of respondents Number of…
  13. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981
    …pt. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 341; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80,191-192. To provide for judicial review of respondent’s determination regarding a retirement plan before a notice of deficiency is issued, Congress enacted section 7476. However, the procedure provided therein is clearly an …
  14. 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
    …3 Areas in which determination letters will not be issued 191 .04 Determination letter applications 192 .05 Review of determination letters 192 SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 193 .01 Scope of this section 193 .02 Scope of determination letters 193 .03 Design-based safe harbor 193 .04 Go…
  15. 88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac…
    IRCProposed Rules (FR)Proposed Jul 12, 2023
    …C.-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2020/​08/​04/​fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insurance.
  16. 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
    …1 .01 Notice to interested parties 191 .02 Time when notice must be given 191 .03 Content of notice 192 .04 Procedures for making information available to interested parties 192 .05 Information to be available to interested parties 193 .06 Special rules if there are fewer than 26 participants 193 .07 Information descri…
  17. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
  18. ERISA § 207 (29 U.S.C. § 1057) — Repealed. Pub. L. 109–280, title I, §108(d), formerly §107(d), Aug. 17, 2006, 120 Stat. 820, renumbered Pub. L. 111–192, title II, §202(a), June 25, 2010, 124 …
    ERISACode / StatuteJan 7, 2011
    …. 109–280, title I, §108(d), formerly §107(d), Aug. 17, 2006, 120 Stat. 820, renumbered Pub. L. 111–192, title II, §202(a), June 25, 2010, 124 Stat. 1297
  19. 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…
  20. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…