Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010related by meaning
URE AND ADMINISTRATION
Paragraph 1.
The authority citation for part 301 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *.
Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows:
§ 301.6404-0
Table of Contents.
* * * * *
§ 301.6404-4 Suspension of interest and c…
PBGCRegulationsJan 22, 2018
…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 computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
75 FR 46844 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Aug 4, 2010related by meaning
on 53.6071-1 is amended by revising paragraph (g)(3) to read as follows:
§ 53.6071-1
Time for filing returns.
* * * * *
(g) * * *
(3)
Transition rule. A Form 4720, for a section 4965 tax that was due on or before October 4, 2007, will be deemed to have been filed on the due date if it was filed by October 4, 2007, and …
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
- 6 -
Respondent does not dispute that petit…
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…
IRCCode / StatuteJan 6, 2025related by meaning
(d)(13) (13) any transaction which is exempt from section 406 of such Act by reason of section 408(e) of such Act (or which would be so exempt if such section 406 applied to such transaction) or which is exempt from section 406 of such Act by reason of section 408(b)(12) of such Act;
(d)(14) (14) any transaction requir…
IRCRegulationsMay 18, 2016related by meaning
(c) (c) Sanctions
(c)(1) (1) Excess contributions. If an individual retirement account or individual retirement annuity accepts and retains excess contributions, the individual on whose behalf the account is established or who is the owner of the annuity will be subject to the excise tax imposed by section 4973.
(c)(2)…
IRCCourt RulingsJan 22, 2025related by meaning
no substantive merit in this
case. Accordingly, we find that petitioner is liable for the addition to tax
under section 6651(a)(1).
B. Failure to Pay Section 6651(a)(2) authorizes the imposition of an addition to tax
for failure to timely pay the amount shown as tax on a f ederal income
tax return unless the taxpayer …
IRCCourt RulingsJun 28, 2017related by meaning
he Commissioner bears the burden of production with respect to penalties.
Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). Once the burden of production is met, the taxpayer must come forward with evidence
sufficient to show that the penalty does not apply. Higbee v. Commissioner, 116
T.C. at 447. Pe…
IRCCourt RulingsFeb 6, 2024related by meaning
icipation. Id.
Thus, even though the withdrawal from the taxpayer’s Keogh account
was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively
receive the funds under section 72(m)(4)(A).
4
In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
IRCPrivate Letter RulingsApr 30, 2010
… April 01, 2010 2:59:47 PM
To: ------------------
Cc:
Subject: RE: ERISA question
The pr ovision 29 USC 1104(b) that you are referring to is section 404(b) of ERISA, that provides that
no fiduciary may maintain the indicia of ownership of any assets of a plan outside the jurisdiction of the
District Courts of the U.S.,…
Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex… IRCNoticesNov 13, 2007related by meaning
g whether an estate making the section 6166 election will be required to provide security.
TAX CONVENTIONS
Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
…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.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation c…
IRCCourt RulingsFeb 9, 2023related by meaning
the purposes of this O pinion, we
conclude without further discussion that the requirement is valid under
Chevron step two.
E. E
xhaustion of remedies Title 26 C.F.R. sec. 1.482-1(h)(2)(ii)(B) (2006) provides that a
foreign legal restriction will be taken into account only if the taxpayer
has exhausted all remedies pre…
PBGCPBGC Opinion LettersSep 30, 1994
…( 4)( B)>
421 9 N otice & Co llection o f W ithdraw al Liab ility
422 1 Reso lution of Disputes
>29 USC 1461 n ote >
OP INI ON :
I
wri te i n res ponse t o your reque st for the opini on
of the Pension Benefit Guaranty Corporation ("PBG C").
Your
fir st r equest c oncerns a par ticu lar
applicat ion of t he princ iples…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…