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74 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …ALTH PLANS Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    statement of income. Treas. Reg. § 301.6501(e)-1. In deciding the va lidity of this regulation, the Supreme Court looked to a pre- Chevron case to see whether that case had left a gap for the agency to fill. The case on which Home Concrete relied expressly held that the statute it was interpreting was ambiguous. In Col…
  3. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  4. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959related by meaning
    s for such determination. Such statement shall not be used in the Tax Court of the United States as proof of the facts or conclusions stated' therein. “This subsection shall be applicable to all contracts and subcontracts, to the extent of the amounts received or accrued thereunder in any fiscal year ending after June …
  5. 29 T.C. 175 — Park Sherman Co. v. United States
    IRCCourt RulingsOct 30, 1957related by meaning
    no evidence whatever to refute respondent’s determination. For failure of proof, we necessarily sustain respondent’s determination as to Bloom-ington. Because of the possibility of minor adjustments indicated by the stipulation of facts filed herein, Decisions will be entered under Bule 50. Sec. 403 (a). For the purpos…
  6. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    nerally presumed correct. Rule 142(a); Welch v. Helvering , 290 U.S. 111, 115 (1933). Furthermore, every item of a person's gross income is subject to Federal income tax unless there is a statute or some rule of law that exempts the person or the item from gross income. HCSC- Laundry v. United States , 450 U.S. 1, 5 (1…
  7. PBGCRegulationsMar 5, 2020
    …lan for a plan year equals the funding target attainment percentage as provided under ERISA section 303(d)(2) and Code section 430(d)(2) determined without regard to the interest rate stabilization provisions of ERISA section 303(h)(2)(C)(iv) and Code section 430(h)(2)(C)(iv). (b)(2) (2) Assets used to determine 4010 f…
  8. 87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities
    IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
    ). However, other personnel from the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follow…
  9. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    Petitioner argued that the Hong Kong & Shanghai Banking Corp. owns Midland Bank, a U.S. bank, but this factor does not affect our conclusion regarding the probable situs of any trust created in connection with the IRA funds transfer. On this record, we conclude that petitioner has failed to show that the $17,558 that h…
  10. 85 FR 6046 — Miscellaneous Corrections, Clarifications, and Improvements
    PBGCFinal Rules (FR)Feb 4, 2020
    the funding shortfall for the plan year as provided under section 303(c)(4) of ERISA and section 430(c)(4) of the Code, with the following exceptions: (i) The funding target used to calculate the 4010 funding shortfall is determined without regard to the interest rate stabilization provisions of section 303(h)(2)(C)(iv…
  11. 87 FR 80042 — Exception for Interests Held by Foreign Pension Funds
    IRCFinal Rules (FR)Dec 29, 2022related by meaning
    ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development. ( printed page 80055) List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended a…
  12. 84 FR 30666 — Miscellaneous Corrections, Clarifications, and Improvements
    PBGCProposed Rules (FR)Proposed Jun 27, 2019
    the funding shortfall for the plan year as provided under section 303(c)(4) of ERISA and section 430(c)(4) of the Code, with the following exceptions: (i) The funding target used to calculate the 4010 funding shortfall is determined without regard to the interest rate stabilization provisions of section 303(h)(2)(C)(iv…
  13. 83 FR 64280 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Dec 14, 2018
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 303 is added at the end of the table to read as follows: Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annu…
  14. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    required to disclose in that return all of the assets that it held at the end of 2005 and the respective yearend values of all of those assets. - 7 - Under IRC section 4979[A](e)(2)(C), all the deemed owned shares of all the disqualified persons with respect to the Law Office of John H Eggertsen P. C. Employee Stock O…
  15. 81 FR 15432 — Annual Financial and Actuarial Information Reporting
    PBGCFinal Rules (FR)Mar 23, 2016
    …lan for a plan year equals the funding target attainment percentage as provided under ERISA section 303(d)(2) and Code section 430(d)(2) determined without regard to the interest rate stabilization provisions of ERISA section 303(h)(2)(C)(iv) and Code section 430(h)(2)(C)(iv). (2) Assets used to determine 4010 funding …
  16. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    urd result. We agree. ,It is a well-established canon of statutory . interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep. Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v. Keystone Consol…
  17. 80 FR 54980 — Reportable Events and Certain Other Notification Requirements
    PBGCFinal Rules (FR)Sep 11, 2015
    …ck to Citation 44.  Such required contributions include quarterly contributions under ERISA section 303(j)(3) and Code section 430(j)(3), liquidity shortfall contributions under ERISA section 303(j)(4) and Code section 430(j)(4), and contributions to amortize funding waivers under ERISA section 303(e) and Code section …
  18. 29 C.F.R. § 4006.5(g) — Exemptions and special rules.
    PBGCRegulationsSep 15, 2025
    …nt rates that would have been used to determine the funding target for the plan under ERISA section 303 for the purpose of determining the plan's minimum contribution under ERISA section 303 for the UVB valuation year if the segment rate stabilization provisions of ERISA section 303(h)(2)(iv) were disregarded. A plan m…
  19. REG-141075-09 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 …
    IRCProposed Rules (FR)Proposed Jun 18, 2012related by meaning
    t satisfied. Illustrations provided in §1.83-3(c)(2) of the regulations demonstrate when a substantial risk of forfeiture will be considered to exist. In addition to providing that a person’s rights in property are subject to a substantial risk of forfeiture if conditioned upon the future performance of substantial ser…
  20. PBGCRegulationsMar 5, 2020
    … shortfall for a plan year equals the funding shortfall for the plan year as provided under section 303(c)(4) of ERISA and section 430(c)(4) of the Code, with the following exceptions: (a)(1)(i) (i) The funding target used to calculate the 4010 funding shortfall is determined without regard to the interest rate stabili…