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'…
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
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 …
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…y Assumption
21,586
1
193.15
4,169,336
0
21,586
2
193.15
8,338,672
4,169,336
21,586
3
193.15
12,508,008
8,338,672
3. Initial Notice of Default E-Delivery and Right to Opt Out:
A. Compensation and Benefits Manager prepares initial notice of default e-delivery and right to opt out (First year)
21,586
0.25
193.15
1,…
88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates PBGCFinal Rules (FR)Nov 7, 2023related by meaning
a speech disability, please dial 7-1-1 to access telecommunications relay services”.
§ 4000.28
[Removed and Reserved]
3. Remove and reserve § 4000.28. PART 4003—RULES FOR ADMINISTRATIVE REVIEW OF AGENCY DECISIONS
4. The authority citation for part 4003 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3).
§ 40…
IRCCourt RulingsDec 11, 2001
…o report $55,075 from a pension plan and that he was liable for the 10-percent
additional tax of $5,508.
During 1997, Union Bank of California (Union Bank) made a
distribution of $55,404.63 from petitioner’s Mitsubishi Electric
America, Inc. (Mitsubishi) 401(k) account. The distribution
included $329.49 of employee con…
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
added to the aggregate unpaid balance of all preceding such payments for which payment was not made when due (including interest), exceeds $1 million. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due.
(2) If a contributing spo…
IRCCourt RulingsFeb 11, 2013
…n "injunction,
mandamus, and restitution, but not compensatory damages." Mertens v. Hewitt
Assocs., 508 U.S. 248, 256 (1993). Although--in many situations--a court of
-(continued...)
-34-
[*34] Assocs., 508 U.S. 248, 256 (1993)). When a fiduciary of a plan governed by
ERISA seeks "to impose a constructive trust or equi…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsFeb 29, 2012
…ded 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. Industries, Inc., 508:U.S. 152, 159 (1993)).
A number·of other statutes apply to an organization exempt from tax under
subtitle A.*Section 6672(a) imposes…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023related by meaning
7805 * * *
* * * * *
Section 1.6033-4 also issued under 26 U.S.C. 6033.
* * * * *
Section 1.6037-2 also issued under 26 U.S.C. 6037.
* * * * *
Par. 2. Section 1.1461-1 is amended by removing paragraph (c)(5); redesignating paragraph (i) as paragraph (j); adding a new paragraph (i); and revising newly redesignated parag…
IRCCourt RulingsDec 5, 2007
…o . , 304 U .S . 282, 294-295 (1938) ; IT&S of Iowa, Inc . v .
- 55 -
Commissioner , 97 T .C . 496, 508 (1991) . We are not bound by an
expert's opinion and will reject an expert's opinion to the
extent that it is contrary to the judgment we form on the basis
of our understanding of the record as a whole . See IT&S of …
Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs… IRCNoticesFeb 9, 2026related by meaning
igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
IRCCourt RulingsApr 2, 2024related by meaning
…th 890, 904 (6th Cir. 2021);
Sunrise Coop., Inc. , 891 F.3d at 656.
Petitioners argue that section 7508A( d ) unambiguously provides
a self- executing postponement period for all of the tax-related acts
included in section 7508(a)(1) by cross-reference to section 7508 A ( a ) . In
their view , the contrast of the discr…
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…
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…
80 FR 79684 — Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated IRCFinal Rules (FR)Dec 23, 2015related by meaning
l for Advocacy of the Small Business Administration for comment on their impact on small business, and no comments were received.
Drafting Information The principal authors of these regulations are Mike Repass and Jonathan Carter, Office of Associate Chief Counsel (Tax-Exempt and Government Entities). However, other pe…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]