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…
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…
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 …
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…
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…
IRCCourt RulingsAug 22, 1994
…contained in section 512(a)(3) as applicable to VEBA’s under the Deficit Reduction Act of 1984. The 1985 proposal suggested that, under general tax principles, the deduction of advanced funding in 1985 would be allowed if the funding did not create a benefit with a useful life of more than 1 year. The 1985 proposal adv…
IRCCourt RulingsAug 13, 1990
…percent interest for plan loans made from 1982 through 1985.
In November 1984, Mr. Leston Seaton, a revenue agent, began an examination of the plan. On January 28, 1985, Mr. Seaton learned that DOL was conducting its own investigation of the plan. Mr. Seaton informed his supervisor, Mr. Jackie Jefferson, of the DOL inv…
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,…
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…
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…
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…
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 …
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 RulingsJun 11, 2004
…t its method of accounting for (accelerating) deductions for employer contributions is described in Rev. Rul. 2002-46,
not Rev. Rul. 90-105. Therefore, IDR No. 10, citing Rev. Rul. 2002-46, placed
Taxpayer
‘s method of accounting under consideration. Taxpayer contends that it
applied for an automatic method change on J…
Rev. Rul. 2005-72 — 2006 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2006 are provided for use in … IRCRevenue RulingsNov 14, 2005related by meaning
…t 2005-80
This announcement provides a settlement initiative under which taxpayers and the Internal Revenue Service may resolve the tax treatment of certain tax transactions. Taxpayers have until January 23, 2006, to file an election indicating their intent to participate in this initiative.
INCOME TAX
Notice 2005-77
T…
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 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…