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81 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …rest—Retirement Investment Advice Regulatory Impact Analysis for Final Rule and Exemptions, pp. 312-318, (April 2016), https://www.dol.gov/​sites/​dolgov/​files/​EBSA/​laws-and-regulations/​rules-and-regulations/​completed-rulemaking/​1210-AB32-2/​ria.pdf. Back to Citation 431.  Employee Benefits Security Administratio…
  2. 81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities
    IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
    …ter X. See 31 CFR 1010.100(e). Back to Citation 2.  31 U.S.C. 5311. Back to Citation 3.  31 U.S.C. 5318. Back to Citation 4.  Treasury Order 180-01 (Jul. 1, 2014). Back to Citation 5.  31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section 403 of the Money Launderin…
  3. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…
  4. I.R.C. § 416(i)(1)(A)(iii) — Special rules for top-heavy plans
    IRCCode / StatuteJan 6, 2025
    …yer is a corporation, any person who owns (or is considered as owning within the meaning of section 318) more than 5 percent of the outstanding stock of the corporation or stock possessing more than 5 percent of the total combined voting power of all stock of the corporation, or (i)(1)(B)(i)(II) (II) if the employer is…
  5. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    l revenue.” Sec. 7805(a); see United States v. Correll, 389 U.S. 299, 306-307 (1967); Durbin Paper Stock Co. v. Commissioner, 80 T.C. 252, 256 (1983). Petitioner has also made the argument that the Secretary's failure to adhere to his customary procedure of issuing final regulations, after a notice and comment period, …
  6. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968related by meaning
    -10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
  7. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
    nt participated in their development. List of Subjects in 26 CFR Part 301 Employment taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301—PROCEDURE AND…
  8. Treas. Reg. § 1.409A-1(d)(3)(i) — Definitions and covered plans.
    IRCRegulationsMay 18, 2016
    … service provider's ownership is determined with application of the attribution rules under section 318 if the service recipient is a corporation, or if the service recipient is an entity that is not a corporation, with application by analogy of the attribution rules under section 318), all relevant facts and circumsta…
  9. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …ining $82, 664.66 earned $4,421.83 (8.96% $82,664.66 218/365). From the total amount involved of $7,318.79, I deducted the $2,000.00 of accrued interest that ALTA repaid the Plan on October 31, 1989 to arrive at the final amount involved of $5,318.79. 22The following annual rates were in effect during this transaction:…
  10. 85 FR 27693 — Effect of Section 67(g) on Trusts and Estates
    IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
    ies). Other personnel from the Treasury Department and the IRS, however, participated in their development. Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…
  11. 77 T.C. 477 — Chapman v. Commissioner
    IRCCourt RulingsAug 24, 1981related by meaning
    in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
  12. T.C. Memo. 2007-333 — Jeanne E. Amarasinghe v. Commissioner
    IRCCourt RulingsNov 6, 2007
    0 in 2003 . On her return, Ms . Amarasinghe reported income of $75,318 as alimony received and did not report any income from pensions and annuities . On May 26, 2006, respondent issued a notice of deficiency to Dr . Amarasinghe and his spouse . Respondent effectively disallowed the Form 1040X amended return and determ…
  13. 29 C.F.R. § 2550.408b-2(e) — General statutory exemption for services or office space.
    ERISARegulationsSep 1, 2017related by meaning
    (e) (e) Transactions with fiduciaries
  14. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …able year. For this purpose, indirect ownership is determined under rules similar to the rules of § 318 but without regard to the family attribution rules of § 318(a)(1). - 100 - D. Section 7491(c) 1. Overview As previously stated, the Commissioner bears the burden of production with respect to an individual taxpayer's…
  15. 78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements
    ERISAFinal Rules (FR)Mar 1, 2013related by meaning
    1.3 Service: copies of documents and pleadings. For section 521 proceedings, this section shall apply in lieu of § 18.3 of this title: (a) In general. Copies of all documents shall be served on all parties of record. All documents should clearly designate the docket number, if any, and short title of all matters. All d…
  16. Circular 230 § 10.3(d)(2) — Who may practice.
    Joint BoardRegulationsDec 30, 2016related by meaning
    failure to file annual registration and other notifications by pension plan), 6652(f) (relating to the failure to file information required in connection with certain plans of deferred compensation), 6692 (relating to the failure to file actuarial report), 7805(b) (relating to the extent to which an Internal Revenue Se…
  17. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …d that, effective as of January 1, 1988, MIT 80 would issue an invoice to MPC in the amount of $301,318.95 for the Contract Renegotiation fee. No such invoice was issued. In the agreement, MPC agreed to pay to MIT 80 a balance due of $1,295,108. This amount included the $301,318.95 that MPC had agreed to pay in exchang…
  18. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  19. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …(Chenery II), 332 U.S. 194, 196 (1947) (describing its holding in SEC v. Chenery Corp. (Chenery I), 318 U.S. 80 (1943)). This means that the SO must clearly set forth the grounds on which he made his determination, so that we don't have to guess. See 4 at 196-97. We should not uphold the notice of determination "simply…
  20. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    419A(i) provides that the regulations shall be promulgated by the Secretary as may be necessary to carry out the purposes of sections 419 and 419A. 9 If the intent of Congress on a matter is clear, then the Secretary must give effect to the unambiguously expressed intent of Congress. Chevron U.S.A. Inc. v. Natural Res…