IRCPrivate Letter RulingsOct 21, 2016
… applies to
nonqualified plans of deferred compensation, including excess benefit plans, in various
revenue rulings. In Rev. Rul. 60-31, Situations 1 – 3, the Service held that a mere
promise to pay, not represented by notes or secured in any way, does not constitute
receipt of income by a cash basis taxpayer. Rev. Rul…
Rev. Proc. 2008-61 — This procedure provides areas affected by section 409A of the Code in which rulings will not be issued. Rev. Proc. 2008-3 modified and amplified. IRCRevenue ProceduresOct 20, 2008related by meaning
… experience with the private letter ruling program, the Service has determined that section 5.08 of Rev. Proc. 2008-3 unnecessarily restricts the ability of the Service to issue private letter rulings under Rev. Proc. 2008-1, 2008-1 I.R.B. 1 and Rev. Proc. 2008-4, 2008-1 I.R.B. 121. For example, the existing no-rule po…
75 FR 65567 — Revised Regulations Concerning Section 403(b) Tax-Sheltered Annuity Contracts; Correction IRCFinal Rules (FR)Oct 26, 2010related by meaning
…e final regulations that are the subject of this correction are under section 403(b)of the Internal Revenue Code.
Need for Correction
As published, final regulations (TD 9340) contain an error that may prove to be misleading and is in need of clarification.
Correction of Publication
Accordingly, the publication of the …
Rev. Rul. 2006-43 — Government pick-up plans; employer contributions; income tax; prospective application. This ruling describes the actions required for a state or its political … IRCRevenue RulingsAug 28, 2006
…contributions to meet the requirements set forth above in paragraph (1) of Law and Analysis in this revenue ruling. The relief provided above for “pick-ups” implemented prior to August 28, 2006, applies only if the actions taken otherwise complied with Rev. Rul. 81-35, Rev. Rul. 81-36, and Rev. Rul. 87-10, and only if …
Rev. Proc. 2014-8 — User fees for employee plans and exempt organizations. Current guidance for complying with the user fee program of the Service as it pertains to requests for l… IRCRevenue ProceduresJan 2, 2014
istrative scrutiny determination
Rev. Proc. 93–41
Adoption agreement
Rev. Procs. 2011–49, 2013–22
Advisory letter
Rev. Procs. 2011–49, 2013–22, 2014–6 Basic plan document
Rev. Procs. 2011–49, 2013–22
Determination letter
Rev. Procs. 2014–6, 2014–9
Dual-purpose IRA
Rev. Procs. 98–59, 2010–48
Group exemption letter
Rev. …
Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o… IRCRevenue RulingsSep 8, 2014
…splaced by the disaster and modifies other requirements of § 142(d) to accommodate this suspension.
Rev. Proc. 2014–51 Rev. Proc. 2014–51 This revenue procedure provides guidance on certain aspects of an entity’s qualification as a real estate investment trust (REIT) in the context of transactions involving debt secure…
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, 2026
term rate is set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570.
Section 467.—Certain Payments for the Use of Property or Services The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570.
Section 468.—Special Rules f…
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 …
IRCCourt RulingsApr 12, 1976
…f simplicity the partial termination of the plan is referred to as the termination of the plan.
See Rev. Rul. 58-94, 1958-1 C.B. 194; Rev. Rul. 58-95, 1958-1 C.B. 197; Rev. Rul. 58-96,1958-1 C.B. 200; Rev. Rul. 58-97,1958-1 C.B. 201; Rev. Rul. 58-98,1958-1 C.B. 202; Rev. Rul. 58-383,1958-2 C.B. 149; Rev. Rul. 65-147,19…
54 T.C. 1057 — Bernard McMenamy, Contractor, Inc. v. Commissioner IRCCourt RulingsMay 25, 1970
…ovision of the regulations was adopted, the respondent issued I.T. 3685, 1944 C.B. 324, restated in Rev. Rul. 68-653,1968-2 C.B. 177; I.T. 3686, 1944 C.B. 326, restated in Rev. Rul. 68-654, 1968-2 C.B. 179; and P.S. No. 28 (1944), restated in Rev. Rul. 68-652, 1968-2 C.B. 176. In these rulings, he made clear that in hi…
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…
IRCCourt RulingsMay 31, 1989
…tions Charles A. Martin (Mr. Martin) founded the employer and was its chief executive officer until 1968. In 1968, the employer’s board of directors elected Mr. Martin chairman of the board and a vice president. Mr. Martin’s annual compensation was fixed at $30,000, and Mr. Martin has continued to work for the employer…
IRCCourt RulingsAug 31, 1978
…ollowing deficiencies in the petitioners’ Federal income taxes:
Docket No. Year Deficiency
8683-74 .1968 $334.00
1969 667.00
8684-74 .1968 1,709.49
1969 3,488.97
By an amendment to his answer, the Commissioner claimed increased deficiencies as follows:
Docket No. Year Deficiency
8683-74 .1968 $714.00
1969 1,429.00
8684…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024related by meaning
…oposed transaction for tax purposes.
Issues under consideration by the PBGC or the DOL .07 A letter ruling relating to an issue that is being considered by the PBGC or the DOL, that involves the same taxpayer, shall be issued at the discretion of Employee Plans Rulings and Agreements.
Domicile in a foreign jurisdiction…
IRCPrivate Letter RulingsFeb 12, 1999
and disbursements method of accounting. See also
Rev. Rul. 69-649,
1969-2 C.B. 106, and Rev. Rul. 69-650, 1969-2 C.B. 106. In Rev. Rul. 72-25, 1972-1 C.B. 127, and Rev. Rul. 68-99, 1968-1 C.B. 193, an employee does not receive income
as a result of the employer's purchase of an insurance contract to provide a source o…
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,…
IRCPrivate Letter RulingsJul 26, 2013related by meaning
…sues addressed in this ruling
have not yet been adopted. Therefore, this ruling will be modified or revoked by
adoption of temporary or final regulations to the extent the regulations are not
i nconsistent with any conclusion in the ruling. See § 11.04 Rev. Proc. 95-1, 1995-1
C.B. 9. However, when the criteria in § 11.…