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80 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. 87 FR 50240 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCFinal Rules (FR)Aug 16, 2022related by meaning
    small business. No comments were received from the Chief Counsel for the Office of Advocacy of the Small Business Administration. Drafting Information The principal author of these regulations is Seth Groman of the Office of Associate Chief Counsel (Tax Exempt and Government Entities), though other persons in the Treas…
  3. Treas. Reg. § 1.410(b)-6(c) — Excludable employees.
    IRCRegulationsSep 9, 2016
    …iens (c)(1) (1) General rule. An employee who is a nonresident alien (within the meaning of section 7701(b)(1)(B)) and who receives no earned income (within the meaning of section 911(d)(2)) from the employer that constitutes income from sources within the United States (within the meaning of section 861(a)(3)) is trea…
  4. Treas. Reg. § 1.421-1(h)(4)(i) — Meaning and use of certain terms.
    IRCRegulationsSep 9, 2016
    … section and §§ 1.421-2 through 1.424-1, the term corporation has the meaning prescribed by section 7701(a)(3) and § 301.7701-2(b) of this chapter. For example, a corporation for purposes of the preceding sentence includes an S corporation (as defined in section 1361), a foreign corporation (as defined in section 7701(…
  5. PLR 201634021 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools
    IRCPrivate Letter RulingsAug 19, 2016
    sociation (and thus a corporation) by filing Form 8832 in accordance with § 301.7701-3(c) or to be disregarded as an entity separate from its owner in accordance with the default classification rules unde r § 301.7701-3(b). If an entity is a disregarded entity, its activities are treated in the same manner as a sole pr…
  6. Treas. Reg. § 1.414(q)-1T(b7)(1)(i)(B) — Highly compensated employee (temporary).
    IRCRegulationsSep 9, 2016
    …ning agreement between employee representatives and the employer, which agreement satisfies section 7701(a)(46) and § 301.7701-17T (Temporary), are included in determining the number of employees in the top-paid group.
  7. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …taxed as a sole proprietorship, from which we infer that it was a disregarded entity. See secs. 301.7701-2(a), 301.7701-3(b)(1)(ii), Proced. & Admin. Regs. That means that Burbach was taxed as a sole proprietor under the Internal Revenue Code on any income or loss of BA, LLC reported on his returns. See sec. 301.7701-2…
  8. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  9. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …tary,” the Code defines that term to mean “the Secretary of the Treasury or his delegate.” I.R.C. § 7701(a)(11)(B); see also I.R.C. § 7701(a)(12) (defining the term “or his delegate”). The Secretary has delegated these duties to the Commissioner, who in turn has delegated them to other Internal Revenue Service (IRS) of…
  10. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
  11. T.C. Summary Opinion 2006-55 — Linda L. & Anthony M. Domanico v. Commissioner
    IRCCourt RulingsApr 19, 2006
    …. 72(t)(2)(A) (e.g., distributions (1) made after the employee attains age 59 ½, (2) (continued...) 7701(a)(37). Retirement plans qualified under section 401(a) and (k), however, are not included in the definition of “individual retirement plan” under section 7701(a)(37). Clearly, Congress intended this exception to ap…
  12. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  13. T.C. Summary Opinion 2006-71 — Richard L. & Stephanie S. Barbee v. Commissioner
    IRCCourt RulingsApr 27, 2006
    l retirement annuity (commonly referred to as IRAs). Sec. 7701(a)(37). Retirement plans qualified under section 401(a) and (k), however, are not - 5 - included in the definition of “individual retirement plan” under section 7701(a)(37). Clearly, Congress intended the exception of section 72(t)(2)(E) to apply only to di…
  14. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009
    …as an early distribution made before petitioner attained the age of 59-1/2 . See secs . 4974(c)(1), 7701(j)(1) . 9 3Sec . 72(t)(1) provides : SEC . 72(t) . 10-Percent Additional Tax on Early Distributions from Qualified Retirement Plans .-- (1) Imposition of additional tax .--If any taxpayer receives any amount from a …
  15. T.C. Summary Opinion 2006-106 — Christine L. Gibbons v. Commissioner
    IRCCourt RulingsJul 13, 2006
    …dividual retirement account or individual retirement annuity (commonly referred to as IRAs) . Sec . 7701(a)(37) . Retirement plans qualified under section 403(b), as in this case, are not included in the definition of "individual retirement plan" under section 7701(a)(37) . Congress intended the exception of section 72…
  16. 76 T.C. 1048 — Arkin v. Commissioner
    IRCCourt RulingsJun 25, 1981
    …t may be that the land trust involved would be considered an association for tax purposes (see sec. 7701(a)(3); sec. 301.7701-2, Proced. & Admin. Regs.; Morrissey v. Commissioner, 296 U.S. 344 (1935); Strong v. Commissioner, 66 T.C. 12 (1976)), and that petitioner would be a shareholder of stock (sec. 7701(a)(7) and (8…
  17. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
    nt participated in their development. List of Subjects in 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301—PROCEDURE AND…
  18. PLR 201538021 — Definition of Employer Securities
    IRCPrivate Letter RulingsSep 18, 2015
    …ock of the employer (or of any other such corporation) having the greatest dividend rights. Section 7701(a) provides definitions of certain terms as they are used in the Code, where not otherwise distinctly expressed or manifestly incompatible with the intent of the Code section in which the term is used. Section 7701(…
  19. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  20. Notice 2009-8 — This notice provides interim guidance on recently enacted section 457A of the Code which became effective January 1, 2009. Section 457A generally provides that…
    IRCNoticesJan 26, 2009
    … 457A? A-7 For purposes of § 457A, the term foreign corporation means a corporation as defined in § 7701(a)(3) that is not domestic as defined in § 7701(a)(4). For purposes of § 457A, the term partnership has the meaning given that term in § 7701(a)(2). Q-8 How is it determined whether substantially all of a foreign co…