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…
IRCPrivate Letter RulingsNov 13, 2015
ed in any way, does not constitute
PLR-T-102477-15
8
receipt of income by a cash basis taxpayer. Rev. Rul. 60-31, 1960-1 C.B. 174, as
modified by Rev. Rul. 64-279, 1964-2 C.B. 121, and Rev. Rul. 70-435, 1970-2 C.B. 100;
see also Rev. Rul. 69-650, 1969-2 C.B. 106, Rev. Rul. 69-649, 1969-2 C.B. 1 06; and
Rev.
Rul. 71-419…
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 …
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. 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 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. 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. …
81 FR 20946 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice ERISAFinal Rules (FR)Apr 8, 2016related by meaning
…-1, Parts II-V; PTE 77-4; PTE 80-83; PTE 83-1: PTE 84-24; and PTE 86-128.
Back to Citation
54.
The revoked exemptions include PTE 75-1, Parts I(b) and (c); PTE 75-1, Part II(2); and parts of PTE 84-2 and PTE 86-128.
Back to Citation
55.
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…
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 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…
Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014
…, must a qualified retirement plan be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice?
A–4. Whether a plan must be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice depends on the terms of the specific plan, as described in Q&…
IRCRegulationsSep 9, 2016
(f)(6) (6) Example. The rules contained in paragraph (f) of this section are illustrated by the following table. In the table, “V” signifies actuarial valuation date (January 1 in each case shown); “B” signifies beginning of a contract; and “E” signifies end of a contract. The table shows the resulting earliest base un…
IRCRegulationsSep 9, 2016
…a)(4) and (b)(2)(i) of this section are illustrated by the following example: Example.On January 1, 1976, employer W became a member of the noncontributory XYZ pension plan which uses the calendar year as the plan year. W did not maintain any plan prior to that date. The plan provided for benefits of $4 per month per y…
IRCCourt RulingsJan 20, 1982
…vath, husband and wife, filed a joint Federal income tax return for the year 1976 with the Internal Revenue Service Center at Fresno, Calif. Petitioners resided in Alamo, Calif., at the time their petition herein was filed.
Petitioner Virginia R. Horvath (Mrs. Horvath) was employed by U.S. Steel Corp. from June 1975 un…
IRCCourt RulingsAug 3, 1979
…439-440, (1976), 1976-3 C.B. (Vol. 2) 1,451-452.
The matter arose again during consideration of the Revenue Act of 1978, Pub. L. 95-600. The Finance Committee expressed concerns similar to those noted above in connection with the Tax Reform Act of 1976. The proposed legislative solution was briefly described as follows…
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…
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…