IRCCourt RulingsJun 4, 1984related by meaning
… Nor, to the best of our knowledge, has any other court done so. Respondent would have us hold that Rev. Rul. 69-494 acquired the force of law when ERISA was enacted. We need not go so far and conclude that, under the facts of this case, the trust did not operate for the exclusive benefit of employees within the meanin…
Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the … IRCRevenue ProceduresJan 4, 2016
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2015-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the … IRCRevenue ProceduresJan 2, 2015
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011–1, together with the trust instrument and related documents. Rev. Rul. 2004–67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
IRCCourt RulingsJan 25, 1968related by meaning
…rence F. Buckley, 29 T.C. 455 (1957). We recognize that the Commissioner issued in 1958 a series of revenue rulings on the question of “separation from the service” as related to corporate acquisitions. See Rev. Ruls. 58-94, 58-95, 58-96, 58-97, 58-98, 58-99, 1958-1 C.B. 194-204. The revenue ruling most like this case …
Rev. Proc. 2013-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresJan 2, 2013
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
IRCCourt RulingsJul 24, 1984related by meaning
…26 C.F.R. sec. 601.201(1)(5) provides, in part, that: "Except in rare or unusual circumstances, the revocation or modification of a ruling will not be applied retroactively with respect to the taxpayer to whom the ruling was originally issued or to a taxpayer whose tax liability was directly involved in such ruling if …
Rev. Proc. 2012-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2012
…or Group or Pooled Trust Ruling, demonstrating how the group trust satisfies the criteria listed in Rev. Rul. 2011-1, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends the ability to participate in group trusts to eligible governmental plans under § 457(b) and clarifies the ability of …
Rev. Proc. 2011-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2011
.02 A request for a determination letter on the status of a group trust as described in Rev. Rul. 81-100 is made by submitting a written request demonstrating how the group trust satisfies the five criteria listed in Rev. Rul. 81-100, together with the trust instrument and related documents. Rev. Rul. 2004-67 extends t…
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…
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 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…
71 T.C. 765 — Elliot Knitwear Profit Sharing Plan v. Commissioner IRCCourt RulingsFeb 12, 1979
…lied to qualified profit sharing plans, too. H. Rept. 91-413 (Part 1), 91st Cong., 1st Sess. 46-47 (1969), 1969-3 C.B. 200, 230; S. Rept. 91-552, 91st Cong., 1st Sess. 67 (1969), 1969-3 C.B. 423, 467. See S. Rept. 1622, 83d Cong., 2d Sess. 313 (1954); Rowley United Pension Fund v. Commissioner, 64 T.C. 343 (1975). See …
PLR 202524006 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsJun 13, 2025
…“group t rust retiree benefit plans,” are qualified retirement plans under § 401(a) of the Internal Revenue Code (Code); governmental retiree benefit
plans under § 401(a)(24); certain custodial accounts under § 403(b)(7); retirement
income accounts under § 403(b)(9 ); IRAs that are exempt under § 408(e); eligible
gover…
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…
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
istration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by § 6103.
DRAFTING INFORMATION The principal author of this revenue procedure is Eric D. Slack of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding how…
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
…
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…
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 …