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73 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    dered a gain from the sale or exchange of a capital asset held for more than 6 months. [Emphasis added.] The Senate report provides in pertinent part: "The provisions of the House bill with respect to section 165(b), concerning the taxation of the beneficiary of a trust which meets the requirements of section 165(a), h…
  2. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    estate, and (ii) IRA 0 to Charity D; and (4) that Taxpayer A will not be subject to Code section 4973 or section 4974 excise taxes with respect to any of the IRAs listed in this ruling request. With respect to your first ruling request, Section 2501 (a) provides that a tax is imposed for each calendar year on the trans…
  3. PLR 201437026 — Taxability of Beneficiary of Employee's Trust (Time and Manner of Taxation)
    IRCPrivate Letter RulingsSep 12, 2014related by meaning
    rmining whether to grant a waiver of the 60-day rollover requirement pursuant to section 402(c)(3) of the Code, the Service will consider all relevant facts and circumstances, including: (1) errors committed by a financial institution; (2) inability to complete a rollover due to death, disability, hospitalization, inca…
  4. Rev. Proc. 2007-71 — Tax-sheltered annuities; written program; public schools; model amendments. This procedure sets forth model amendments that may be adopted in order to satisfy …
    IRCRevenue ProceduresDec 17, 2007related by meaning
    y’s interest in the transferor plan (e.g., a pro rata portion of the Participant’s or Beneficiary’s interest in any after-tax employee contributions). (c) Upon the transfer of assets under this Section 6.3, the Plan’s liability to pay benefits to the Participant or Beneficiary under this Plan shall be discharged to the…
  5. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    Petitioner argued that the Hong Kong & Shanghai Banking Corp. owns Midland Bank, a U.S. bank, but this factor does not affect our conclusion regarding the probable situs of any trust created in connection with the IRA funds transfer. On this record, we conclude that petitioner has failed to show that the $17,558 that h…
  6. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
  7. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    egal effect to proof that a transfer was made for a fair consideration". Farid-Es-Sultaneh v. Commissioner, supra at 814. The court thus held that the taxpayer had acquired the stock by purchase despite the afact that the transferor could have been liable for gift tax if the gift tax had been in effect at the time of t…
  8. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
  9. PLR 201117001 — Grandfather Clause
    IRCPrivate Letter RulingsApr 29, 2011related by meaning
    Internal Revenue Service Department of the Treasury Wa shington, DC 20224 Number: 201117001 Release Date: 4/29/2011 Index Number: 457.11-00 ------------------ ---------------------------------------------------------- -------------------------------- ----- ---------------------------- Third Party Communication: None Da…
  10. PLR 200814005 — Investment in Contract
    IRCPrivate Letter RulingsApr 4, 2008related by meaning
    Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 200814005 Release Date: 4/4/2008 Index Numbers: 72.02-00, 848.00-00, 7702.00-00 -------------------------- ------------------------------------------------------------ ------------------ ---------------------------------- -----------------…
  11. I.R.C. § 501(h)(8) — Exemption from tax on corporations, certain trusts, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (h)(8) (8) Affiliated organizations For rules regarding affiliated organizations, see section 4911(f).
  12. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    … HHS and Transportation ability to conduct these analyses. E. Regulatory Flexibility Act The RFA (5 USC 601, et seq.), requires agencies to prepare an initial regulatory flexibility analysis to describe the impact of these proposed rules on small entities, unless the head of the agency can certify that the rule will no…
  13. T.C. Memo. 2015-208 — Stephen J. Dunn & Geri L. Dunn v. Commissioner
    IRCCourt RulingsOct 26, 2015related by meaning
    egs., supra (contribution "shall be treated as made on account of [a] taxable year if it is irrevocably specified in writing to the trustee, insurance company, or custodian that the amounts contributed are for such taxable year"). The proposed regulations include no suggestion that a contribution, once so designated, c…