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80 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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 …
  3. Rev. Proc. 2015-28 — This revenue procedure contains modifications to Revenue Procedure 2013–12, 2013–4 I.R.B. 313. The modifications reflected in this revenue procedure include ne…
    IRCRevenue ProceduresApr 20, 2015related by meaning
    2013–12 is modified by this revenue procedure. SECTION 6. EFFECTIVE DATE This revenue procedure is effective April 2, 2015. SECTION 7. PUBLIC COMMENTS The Treasury Department and the Service invite comments on this revenue procedure. Send submissions to CC:PA:LPD:PR, (Rev. Proc. 2015–28), Room 5203, Internal Revenue Se…
  4. Treas. Reg. § 1.410(b)-7(c)(4)(i)(D) — Definition of plan and rules governing plan disaggregation and aggregation.
    IRCRegulationsSep 9, 2016
    ce 1989 and worked for Division M from 1981 to 1988. Employee C has worked in the headquarters of Employer X since 1981. For the period 1981 to 1988 Employee C was credited with years of service under Plan P. (b) For purposes of the benefits accrued by Employee A under Plan P during years 1981 through 1997, Employee A …
  5. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    urt has taken in later cases, such as those noted earlier herein, is a matter that we need not consider. The plain fact is that it is distinguishable. We find support, at least to some extent, for our conclusion that the provision under attack is constitutional in the numerous recent cases interpreting section 2035 wit…
  6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    as in fact only $7,992,215. The deductible contribution amount for the 1988 plan year was $13,243,405. 5 During the 1988 year, $4,092,000 was paid for PRMB's. Accordingly, the increase in the required reserve at the 1988 plan yearend is $9,151,405 ($13,243,405 less $4,092,000). Consequently, the total reserve balance s…
  7. PLR 201330016 — Required Distributions Where Holder Dies
    IRCPrivate Letter RulingsJul 26, 2013related by meaning
    …sues addressed in this ruling have not yet been adopted. Therefore, this ruling will be modified or revoked by adoption of temporary or final regulations to the extent the regulations are not i nconsistent with any conclusion in the ruling. See § 11.04 Rev. Proc. 95-1, 1995-1 C.B. 9. However, when the criteria in § 11.…
  8. 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,…
  9. Rev. Proc. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela…
    IRCRevenue ProceduresModified Jan 2, 2013related by meaning
    … or determination letters on whether a cafeteria plan satisfies the requirements of § 125. See also Rev. Proc. 2013-3, also in this Bulletin, for areas under the jurisdiction of the Division Counsel/ Associate Chief Counsel (Tax Exempt and Government Entities) involving cafeteria plans in which advance rulings or deter…
  10. 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…
  11. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    … are, by contract, mechanical and predictable. Whether the private letter rulings, plus the TAM and Rev. Rul. 76-28, rise to the level of "longstanding administrative practice" is, to say the least, problematical, but in any event, as the Supreme Court has stated in Dixon v. United States , 381 - 29 - U.S. 68, 73 (1965…
  12. 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…
  13. 76 FR 66136 — Investment Advice-Participants and Beneficiaries
    ERISAFinal Rules (FR)Oct 25, 2011related by meaning
    … 17, 1978), 5 U.S.C. App. 1, 92 Stat. 3790, the authority of the Secretary of the Treasury to issue rulings under section 4975 of the Code has been transferred, with certain exceptions not here relevant, to the Secretary of Labor. Therefore, the references in this notice to specific sections of ERISA should be taken as…
  14. 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 …
  15. PLR 199905003 — Nonqualified Annuities
    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…
  16. PLR 200424004 — Year of Deduction
    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…
  17. PLR 199912002 — Year of Deduction
    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…
  18. PLR 199910006 — Deferred Compensation
    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…
  19. 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 …
  20. 58 T.C. 115 — Doing v. Commissioner
    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…