Search the Pension Law Library

61. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
62. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024related by meaning
    …)(G); Funk , 123 T.C. at 218; Swain v . Commissioner, 118 T.C. 358 , 363 – 65 (2002); Barrios, T.C. Memo. 2023 - 32, at *7. However, the Petition appears to assign error —at least indirectly —to the addition to tax for failure to timely pay. Section 6651(a)(2) provides for an addition to tax when a taxpayer fails to pa…
63. T.C. Memo. 2018-49 — Stacey S. Marks v. Commissioner
    IRCCourt RulingsApr 10, 2018related by meaning
    bution out of an IRA that is then paid into another IRA owned by the same owner within 60 days. Id. Under section 408(e)(2)(A), if an IRA engages in a prohibited transaction, the account ceases to be an IRA as of the first day of the taxable year in which the prohibited transaction occurs. - 4 - [*4] Respondent's posit…
64. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    3. Section 301.6033-5 is added to read as follows: § 301.6033-5 Disclosure by tax-exempt entities that are parties to certain reportable transactions. (a) In general. For provisions relating to the requirement of the disclosure by a tax-exempt entity that it is a party to certain reportable transactions, see § 1.6033-5…
65. REG-148326-05 — Proposed regulations address the calculation of amounts includible in income under section 409A(a) of the Code and the additional taxes imposed by such section…
    IRCProposed Rules (FR)Proposed Dec 22, 2008
    …pothetical underpayment for 2020. Example 2. The facts are the same as in Example 1, except that in 2018, Employee N had an excess charitable contribution the deduction of which was not permitted under section 170(b), and which was carried over to subsequent taxable years under section 170(d). For purposes of determini…