IRCPrivate Letter RulingsMay 8, 2015
. Rev. Rul. 77-85, 1977-1 C.B. 12, Rev. Rul. 80-274, 1980-2 C.B. 27,
Rev. Rul. 81-225, Rev. Rul. 82-54, 1982-1 C.B. 11, Rev. Rul. 2003-91, 2003-2 C.B. 347, and Rev. Rul. 2003-92, 2003-2 C.B. 350. The rulings stand for the proposition that
contract holders possessing control over the investment of the separate account a…
IRCPrivate Letter RulingsAug 27, 1999
…al
or is not relevant to the issue presented in this
technical advice request.
5
The application of Rev. Rul. 54-608 was delayed by Rev. Rul. 55-246,
1955-1 C.B. 68; Rev. Rul. 56-315, 1956-2 C.B. 304; Rev. Rul. 57-28, 1957-1
C.B. 193; and Rev. Rul. 57-325, 1957-2 C.B. 302. Congress further delayed the
application of Re…
IRCPrivate Letter RulingsOct 13, 2006
…ge for such insurance is unreasonably large in
relation to the total charges under the contract.
In Rev. Rul. 75-302 , 1975-2 C.B. 86, Rev. Rul. 75-303, 1975-2 C.B. 87, and Rev. Rul. 76 -
481, 1976-2 C.B. 82, taxpayers were allowed a current deduction of payments for future medical
care extendi ng substantially beyond …
Rev. Rul. 2008-13 — Performance-based compensation. This ruling holds that compensation paid to an executive is not qualified performance-based compensation for purposes of sectio… IRCRevenue RulingsMar 10, 2008
INCOME TAX
Rev. Rul. 2008-11 Rev. Rul. 2008-11
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2008.
Rev. Rul. 2008-12 Rev. Rul. 2008-12
Application o…
IRCCourt RulingsMar 31, 1970
30, 1965, Utilities was indebted to that corporation in the amount of $7,500. The liabilities of Utilities per books exceeded its assets by $1,483.10. The petitioner was organized on August 17, 1965, by Homer A. Hunter and R. Frederick Hunter. On August 26, 1965, acting on behalf of herself and as administratrix of her…
IRCCourt RulingsAug 11, 1980
and Effects,” 52 Minn. L. Rev. 1198 (1968); H. Dederick, “What Constitutes Discrimination in Pension and Profit-Sharing Plans?”, 22 J. Tax. 272(1965). An approach more favorable to petitioners would include in the computations Higgins’ Social Security (PICA) contributions. Liberty Machine Works, Inc. v. Commissioner, 6…
PLR 200202027 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 11, 2002related by meaning
…orary or final regulations are inconsistent with any
conclusion in the ruling. See section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46. However, when the criteria in section 12.05 of Rev. Proc. 2001-1 are satisfied, a ruling
is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely…
IRCPrivate Letter RulingsOct 5, 2012
…counting Principles, a synthetic lease is viewed as a secured loan by the IRS for tax purposes."
20
Rev. Rul. 77-85, 1977-1 C.B. 12; Rev. Rul. 80-274, 1980-2 C.B. 27; Rev. Rul. 81-225, 1981-2 C.B. 12; and Rev. Rul. 82-55, 1982-1 C.B. 12. See
also Rev. Proc. 99-44, 1999-2 C.B. 598.
21
Rev. Rul. 2003-91, 2003-2 C.B. 347,…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007
INCOME TAX
Rev. Rul. 2007-34 Rev. Rul. 2007-34
LIFO; price indexes; department stores. The March 2007 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referen…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005
…)(v) of the Code and the applicable mortality table under § 417(e)(3)(A)(ii)(I) of the Code. (New). Rev. Rul. 2002-42, 2002-1 C.B. 76, provides guidance with respect to a situation where a money purchase pension plan is merged or converted into a profit sharing plan.
Rev. Proc. 2002-21, 2002-1 C.B. 911, provides guidan…
IRCPrivate Letter RulingsApr 10, 2015
… Service applied these general tax ownership principles in a series of “investor
con trol” rulings. Rev. Rul. 77-85, 1977-1 C.B. 12, Rev. Rul. 80-274, 1980-2 C.B. 27,
Rev. Rul. 81-225, Rev. Rul. 82-54, 1982-1 C.B. 11, Rev. Rul. 2003-91, 2003-2 C.B.
347, and Rev. Rul. 2003-92, 2003-2 C.B. 350. The rulings stand for the …
IRCPrivate Letter RulingsFeb 5, 1999
ions.
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 that a mere promise to pay, not represented by notes or secured in any way, does not
constitute receipt of income within the meaning of the cash…
IRCPrivate Letter RulingsJun 11, 2004
…t its method of accounting for (accelerating) deductions for employer contributions is described in Rev. Rul. 2002-46,
not Rev. Rul. 90-105. Therefore, IDR No. 10, citing Rev. Rul. 2002-46, placed
Taxpayer
‘s method of accounting under consideration. Taxpayer contends that it
applied for an automatic method change on J…
IRCPrivate Letter RulingsMar 26, 1999
ion arrangements. Rev. Rul. 60-31, Situations 1-3
, 1960-1 C.B.
174, holds that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income within the meaning of the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Re…
IRCPrivate Letter RulingsJun 29, 2018related by meaning
…and accompanied by a penalty of perjury statement executed
by an appropriate party, as specified in Rev. Proc. 2018-1, 2018-1 I.R.B. 1,
§ 7.01(16) (b). This office has not verified any of the material submitted in support of the
request for ruling, and such material is subject to verification on examination. The
Associ…
IRCPrivate Letter RulingsMar 12, 1999
…he 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 that a mere promise to pay, not represented by notes or se…
IRCCourt RulingsMay 27, 1968related by meaning
…ther cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, where respondent approved a salaried-only classification with respect to an employer who had S3 hourly paid employees and 26 salaried employees…
IRCCourt RulingsApr 25, 1972
…at the distribution of all funds of a pension trust to the employee participants, each of whom has previously executed and who thereafter carries out a legally enforceable agreement to pay over his distributive share to a new pension trust which, like the former, constitutes a qualified trust under section 401(a) of th…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…ermitting the limitations of section 415 to be incorporated by reference under the terms of a plan.
Rev. Rul. 95-6, 1995-1 C.B. 80, and Rev. Rul. 2001-62, 2001-2 C.B. 632, (superseding Rev. Rul. 95-6) provide mortality tables to be used to make certain form adjustments to benefits under a defined benefit plan for purpo…