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41. PLR 201643014 — Qualified Governmental Excess Benefit Plans
    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…
42. 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 …
43. 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. …
44. 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…
45. PLR 201519001 — Included vs. Not Included in Gross Income
    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…
46. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    l Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004. EMPLOYMENT TAX Rev. Rul. 2009-39 Rev. Rul. 2009-39 94X examples revenue ruling. This revenue ruling illustrates the application of the interest-free adjustment and claim for refund processes under the final regulations p…
47. PLR 200641008 — Governmental Plan
    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 …
48. 66 T.C. 82 — Sarmir v. Commissioner
    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…
49. 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&…
50. Rev. Rul. 2008-13 — Performance-based compensation. This ruling holds that compensation paid to an executive is not qualified performance-based compensation for purposes of sectio…
    IRCRevenue RulingsMar 10, 2008
    INCOME TAX Rev. Rul. 2008-11 Rev. Rul. 2008-11 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2008. Rev. Rul. 2008-12 Rev. Rul. 2008-12 Application o…
51. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993
    …operty law see Capíes, “Erisa, Preemption and California Community Property Law,” 22 Santa Clara L. Rev. 33 (1982); Quirk, “State Community Property laws: Coping with Federal Tax and Pension Laws,” 19 Gonzaga L. Rev. 481, 500-509 (1983/84); Comment, “The Employee’s Retirement Income Security Act of 1974 — The Spouse’s …
52. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    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…
53. PLR 201240018 — Included vs. Not Included in Gross Income
    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,…
54. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    ess., 1962-3 C.B. 261, 268-269. All of these rulings have been declared obsolete. Rev. Rul. 72-488, 1972-2 C.B. 649; Rev. Rul. 72-92, 1972-1 C.B. 408. Although petitioner does not directly argue that the regulation is void, it would, in effect, have us invalidate all of the regulations mentioned above. Because this Cou…
55. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004related by meaning
    …ress took a similar approach in section 4951, enacted by section 4(c)(1) of the Black Lung Benefits Revenue Act of 1977, Pub. L. 95-227, 92 Stat. 11, 18. d. Prohibited Transactions Each of the transactions, listed supra in table.1, was a loan. Respondent does not contend that any of the transactions fits under section …
56. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007
    INCOME TAX Rev. Rul. 2007-34 Rev. Rul. 2007-34 LIFO; price indexes; department stores. The March 2007 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referen…
57. 84 FR 33002 — Organizations Under Common Control; Eighty Percent Control Test for a Brother-Sister Controlled Group; Correcting Amendment
    IRCFinal Rules (FR)Jul 11, 2019related by meaning
    …ry Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 8179] AGENCY: Internal Revenue Service. ACTION: Correcting amendment. SUMMARY: This document contains a correction to Treasury Decision 8179, which was published in the Federal Register …
58. PLR 201626003 — Exceptions
    IRCPrivate Letter RulingsJun 24, 2016
    …l the assets have been distribu ted to participants in accordance with the terms of the plan. Under Revenue Ruling 79-237, 1979-2 C.B. 190 (Rev. Rul. 79-237), once applicable, the minimum funding standards described in section 412 apply to a pension plan through the date of its termination. Rev. Rul. 79-237 defines the…
59. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    …)(v) of the Code and the applicable mortality table under § 417(e)(3)(A)(ii)(I) of the Code. (New). Rev. Rul. 2002-42, 2002-1 C.B. 76, provides guidance with respect to a situation where a money purchase pension plan is merged or converted into a profit sharing plan. Rev. Proc. 2002-21, 2002-1 C.B. 911, provides guidan…
60. PLR 201515001 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsApr 10, 2015
    … Service applied these general tax ownership principles in a series of “investor con trol” rulings. 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 …