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…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…ing Department of Labor claims procedure regulation. That is, the Department of Labor interprets 29 USC 1133 and the DOL claims procedure regulation as already requiring that plans provide claimants with new or additional evidence or rationales upon request and an opportunity to respond in certain circumstances.
See
Br…
85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCProposed Rules (FR)Proposed Apr 24, 2020related by meaning
ducted from total UBTI in the manner that results in maximum utilization of the pre-2018 NOLs in a taxable year.
c. Legislative Changes to Section 172 At the same time Congress added section 512(a)(6), it also made extensive changes to section 172. These changes included limiting the NOL deduction to 80 percent of taxa…
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
… read as follows:
Authority:
2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
5. Add § 147.108 to read as follows:
§ 147.108
Prohibition of preexisting condition exclusions.
(a)
No preexisting condition exclusions
—(1)
In general.
A …
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
340.
See,
for example, the proposed 2027 HHS notice of benefit and payment parameters (9…
IRCRegulationsMay 18, 2016related by meaning
(b)(2)(ii) (ii) Accumulated benefit. The condition in paragraph (b)(2)(i)(B) of this section is satisfied if the exchange would satisfy section 414(l)(1) if the exchange were a transfer of assets.
PBGCFinal Rules (FR)Sep 22, 2022related by meaning
ned that this action is not a “significant regulatory action” under the criteria set forth in Executive Order 12866.
List of Subjects
29 CFR Part 4000 Administrative practice and procedure
Pension insurance
29 CFR Part 4233
Employee benefit plans
Pension insurance
Reporting and recordkeeping requirements
29 CFR Part 49…
IRCCourt RulingsFeb 9, 2023related by meaning
eject administrative constructions
which are contrary to clear congressional intent.”)
Ark . A
FL- CIO v. FCC, 11 F.3d 1430, 1440 (8th Cir. 1993).
193 Sec . 482 also authorizes allocations of income between related businesses if
“ necessary in order to prevent evasion of taxes” . Respondent does not argue that this
bas…
IRCRegulationsSep 9, 2016related by meaning
Separate application of section 129(d)(8). [Reserved]
REG-113792-13 — These proposed regulations provide guidance on the tax credit available to certain small employers that offer health insurance coverage to their employees unde… IRCProposed Rules (FR)Proposed Sep 16, 2013related by meaning
ed to taxable years beginning in 2014.
H. Trusts, estates, regulated investment companies, real estate investment trusts and cooperative organizations Section 45R(e)(5)(B) provides that rules similar to the rules of section 52(c), (d) and (e) will apply. Because section 45R(f) explicitly provides that a tax-exempt elig…
PLR 200301032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 3, 2003related by meaning
y time. However, income is not constructively received if the taxpayer's
control of its receipt is subject to substantial limitations or restrictions. Various revenue rulings have considered the tax consequences of nonqualified
deferred compensation arrangements. Rev. Rul. 60-31, Situations 1-3
, 1960-1 C.B.
174, holds…
I.R.C. § 409A(b)(4) — Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans IRCCode / StatuteJan 14, 2019related by meaning
(b)(4) (4) Income inclusion for offshore trusts and employer's financial health For each taxable year that assets treated as transferred under this subsection remain set aside in a trust or other arrangement subject to paragraph (1), (2), or (3), any increase in value in, or earnings with respect to, such assets shall …
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
and thus may provide a certification to a transferee.
See
§§ 1.1445-2(b)(2)(i) (flush language) and 1.1445-5(b)(3)(ii)(A).
B. Section 1446 Withholding A partnership generally must pay a withholding tax under section 1446 on effectively connected taxable income (“ECTI”) allocable under section 704 to a foreign partner. …
IRCFinal Rules (FR)Aug 26, 2022
…s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
114.
2 U.S.C. 1501
et seq.
(1995).
Back to Citation
115.
See House Conf. Rep. No. 104-73…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b) IRCFinal Rules (FR)Oct 21, 2024related by meaning
and diplomatic post office addresses the same as residence addresses located within the United States for purposes of income tax
( printed page 84082) withholding, and payors of distributions from retirement plans and annuities are already processing distributions to payees with residence addresses located within the U…
I.R.C. § 404(a)(1)(C) — Deduction for contributions of an employer to an employees' trust or annuity plan and compensation under a deferred-payment plan IRCCode / StatuteJan 5, 2015related by meaning
(a)(1)(C) (C) Certain collectively-bargained plans In the case of a plan which the Secretary of Labor finds to be collectively bargained, established or maintained by an employer doing business in not less than 40 States and engaged in the trade or business of furnishing or selling services described in section 168(i)(…
88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCProposed Rules (FR)Proposed Sep 26, 2023
…the No Surprises Act.
U.S.C.-Brookings Schaeffer on Health Policy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/.
Back to Citation
127.
United States Census Bureau (March 2020).
2017 SUSB Annual Data Tables by Establishm…
88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements IRCProposed Rules (FR)Proposed Aug 30, 2023related by meaning
s.gov (preferred) or by telephone
at (202) 317-6901 (not a toll-free number) by at least November 15, 2023.
Statement of Availability of IRS Documents Guidance cited in this preamble is published in the Internal Revenue Bulletin and is available from the Superintendent of Documents, U.S. Government Publishing Office, W…