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…
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…
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…
IRCPrivate Letter RulingsJun 2, 2017related by meaning
e xamination. The Associate office will revoke
PLR - 131151-16 4
or modify a letter ruling and apply the revocation retroactively if there has been a misstatement or omission of controlling facts; the facts at the time of the transaction are
materially different from the con trolling facts on which the ruling was based…
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
…
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 …
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…
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. …
PLR 200302032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 10, 2003related by meaning
…ations are inconsistent with any
- 5 -
PLR-158362-01
conclusion in the ruling. See section 12.04 of Rev. Proc. 2002-1, 2002-1 I.R.B. 1, 50. However, when the criteria in section 12.05 of Rev. Proc. 2002-1 are satisfied, a ruling
is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely…
IRCCourt RulingsMay 2, 1978
… to and paid the penalty prescribed by section 72(m)(5)(B) for such distributions. From January 24, 1969, to December 1969, the petitioner did not participate in any qualified retirement plan. In December 1969, the partnership signed a joinder to the master plan maintained by Pittsburgh National Bank and thereby establ…
IRCPrivate Letter RulingsNov 3, 2006related by meaning
006-1, 2006-1 I.R.B. 1, 49. However, when the
PLR-158734-05
4
criteria in section 11.06 of Rev. Proc. 2006-1 are satisfied, a ruling is not revoked or modified retroactively except in rare or unusual circumstances.
Sincerely,
Robert D. Patchell
Chief, Qualified Plans Branch 2
Office of the Associate Chief Counsel
(Tax …
IRCCourt RulingsMay 30, 1984
…e if it meets the requirements of that provision. Although many organizations apply to the Internal Revenue Service for "exemption certificates,” the law does not require them to do so. * * * [H. Rept. 91-413, at 37 (1969), 1969-3 C.B. 200, 224. See also S. Rept. 91-552, at 53 (1969), 1969-3 C.B. 423, 458.][]
The city …
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
…ractice is subject to a number of limitations. See Caplin, "Taxpayer Rulings Policy of the Internal Revenue Service: A Statement of Principles,” 20th Ann. N.Y.U. Tax Inst. 1, 19-22 (1962). For example, a private ruling is controlling only with respect to the specific facts presented and may not be relied upon if there …
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…
IRCCourt RulingsSep 19, 1978related by meaning
…d part of our analysis, relating to the effect of unforeseen circumstances on respondent’s right to revoke his prior ruling. Respondent has publicly announced that a ruling will, in the absence of unusual circumstances, not be revoked retroactively. Statement of Procedural Rules, 26 C.F.R. sec. 601.201 (1977); Rev. Pro…
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…