Rev. Proc. 2014-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela… IRCRevenue ProceduresJan 2, 2014related by meaning
…7). These matters are generally handled by the Employee Plans Determinations program as provided in Rev. Proc. 2014–6, this Bulletin, Rev. Proc. 93–10 and Rev. Proc. 93–12. Although the Employee Plans Technical office will not ordinarily issue rulings on matters involving plan qualification, a ruling may be issued wher…
73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979related by meaning
… We sustain respondent's determination. Respondent is authorized to determine the extent to which a revocation of a determination letter will be applied without retroactive effect. Sec. 7805(b); sec. 301.7805-1(b), Proced. & Admin. Regs. 10 We must uphold the retroactive revocation in the instant case unless respondent…
IRCCourt RulingsSep 29, 1987related by meaning
…x Reform Act of 1986 (sec. 4972, I.R.C. 1986) imposing certain taxes for overfunding pension plans. Rev. Rul. 73-206, 1973-1 C.B. 142, revoked by Rev. Rul. 74-385, supra, involved a situation where employer contributions under a money purchase pension plan were geared to employee contributions under the plan. It was de…
IRCCourt RulingsOct 2, 1974
…4.15 (plus interest not herein material) to Marine Midland Trust Co. of Rochester, N.Y., which had previously qualified as successor trustee of the B-G plan. This sum represented the entire amount accrued on the books of B-G which had not previously been actually paid under the plan.
The following is a transcript of de…
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…
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, 2013related by meaning
…7). These matters are generally handled by the Employee Plans Determinations program as provided in Rev. Proc. 2013-6, this Bulletin, Rev. Proc. 93-10 and Rev. Proc. 93-12. Although the Employee Plans Technical office will not ordinarily issue rulings on matters involving plan qualification, a ruling may be issued wher…
Rev. Proc. 2013-8 — 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 ProceduresModified Jan 2, 2013
etermination Rev. Proc. 93-41
Adoption agreement Rev. Proc. 2011-49
Advisory letter Rev. Procs. 2011-49, 2013-6
Basic plan document Rev. Proc. 2011-49 Determination letter Rev. Procs. 2013-6, 2013-9
Dual-purpose IRA Rev. Procs. 98-59, 2010-48
Group exemption letter Rev. Proc. 80-27
Information letter Rev. Proc. 2013-4
…
IRCCourt RulingsDec 2, 1981related by meaning
…ority of the "otherwise provided” language of that Rule.
A11 section references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Respondent’s reasoning for not sending a determination letter previously was that petitioner had no employees.
Sec. 7476 provides in pertinent part:
SEC. 7476…
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 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…
Rev. Rul. 2004-12 — Plan qualification; rollovers. This ruling describes a situation where an eligible retirement plan separately accounts for amounts attributable to rollover con… IRCRevenue RulingsFeb 17, 2004related by meaning
…es and between § 457 eligible governmental plans.
DRAFTING INFORMATION The principal author of this revenue ruling is Roger Kuehnle of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding this revenue ruling, please contact Employee Plans’ taxpayer assistance telephone serv…
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 RulingsMar 26, 1979related by meaning
…other day. We recognize that our reasoning and the conclusion which flows therefrom are contrary to Rev. Rul. 67-258, supra. But it has long been held that the courts are not bound by revenue rulings since, as we stated in Estate of Lang v. Commissioner, 64 T.C. 404, 407 (1975), on appeal (9th Cir., Jan. 6, 1976), they…
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…
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…
IRCPrivate Letter RulingsMar 16, 2018related by meaning
…and accompanied by a penalty of perjury statement executed by an appropriate party, as specified in Rev. Proc. 2017-1, 2017-1 I.R.B. 1,
§ 7.01(15)(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
Associa…
IRCPrivate Letter RulingsJul 19, 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…
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 …
89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities IRCFinal Rules (FR)Apr 25, 2024related by meaning
)(i), as contained in 26 CFR part 1, revised as of April 1, 2024.
Douglas W. O'Donnell,
Deputy Commissioner.
Approved: April 2, 2024.
Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy).
Footnotes
1.
PLR 200923001 (February 26, 2009).
Back to Citation
2.
See also
STAFF OF THE JOINT COMM. ON TAX'…
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. …