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…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016related by meaning
sing Form 8821, Tax Information Authorization. (See Form 8821 and Instructions) See section 10.09 for special rules relating to Anonymous Submissions. .08 Penalty of perjury statement. (1) The Plan Sponsor must sign the penalty of perjury statement on the Form 8950 as part of a VCP submission. In addition, the followin…
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 of the Code and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
Joint BoardRegulationsDec 30, 2016related by meaning
(b) (b) Depositions upon oral examination
(b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters.
(b)(2) (2) In ordering a depos…
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
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 of the Internal Revenue Code of 1986 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
IRCCourt RulingsMay 9, 2002
…authority to
settle the matter, and that, if there was a settlement, a closing
agreement under sec. 7121 was required. We see no reason in
visiting these questions.
contract is an objective manifestation of mutual assent to
its essential terms. * * * Mutual assent generally requires
an offer and an acceptance. [ Dorche…
IRCCourt RulingsApr 30, 2003
…(d); Rev. Proc.
98-54, 1998-2 C.B. 529. Congress has provided that closing
agreements under section 7121 and compromise agreements under
section 7122 are the exclusive means by which the IRS can
administratively settle civil tax disputes with finality. See
Botany Worsted Mills v. United States
, 278 U.S. 282, 288 (1929…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
Rev. Proc. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresModified Jan 2, 2013
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
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…
ERISARegulationsJan 1, 2017related by meaning
(n) (n) 502(c)(6) civil penalty proceeding means an adjudicatory proceeding relating to the assessment of a civil penalty provided for in section 502(c)(6) of ERISA;
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of … IRCRevenue ProceduresModified Dec 29, 2025
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A closing agreement may be entered into if it is advantageous to have the matter permanently and conclusively closed, or …
IRCCode / StatuteJan 6, 2025related by meaning
(u)(3) (3) Certain retroactive adjustments not required For purposes of this subchapter and subchapter E, no provision of chapter 43 of title 38, United States Code, shall be construed as requiring—
(u)(3)(A) (A) any crediting of earnings to an employee with respect to any contribution before such contribution is actua…
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
imilar settlement.
(a)
Reportable event.
Advance notice is required for an insolvency or similar settlement, as described in § 4043.35.
(b)
Extension. For a case or proceeding under § 4043.35(a)(1) or (2) that is not commenced by a member of the plan's controlled group, the notice date is extended to 10 days after the …
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A closing agreement may be entered into if it is advantageous to have the matter permanently and conclusively closed, or …
ERISACode / StatuteJan 4, 1995related by meaning
(a)(6) (6) such other matter as any of the committees referred to in section 1221 of this title may refer to it.
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A closing agreement may be entered into if it is advantageous to have the matter permanently and conclusively closed, or …
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
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
…ervice and a taxpayer on a specific issue or liability. It is entered into under the authority in § 7121 and is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown.
A closing agreement may be entered into if it is advantageous to have the matter permanently and conclusively closed, or …