IRCCourt RulingsFeb 9, 2023related by meaning
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsDec 29, 2005related by meaning
e 4
- 10 -
of Exhibits 12-P and 16-P. We disagree. Page 4 of those
Exhibits does not so state.
To qualify under section 501(c)(18), the plan must have been funded solely by employee contributions. There is no
evidence of the source of funding of the French pension plan
other than petitioner's $1,916 payment in 2001.
To…
IRCCourt RulingsFeb 28, 2024related by meaning
years
beginning after the date of enactment of the Act); id. § 311(b)(2), 136
Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received).
“This is the highly reticul…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… increased use of less costly providers and triggered provider competition,
33 Health Affairs 1391, 1398 (2014),
https://www.healthaffairs.org/doi/10.1377/hlthaff.2014.0168.
Back to Citation
191.
Sze-jung Wu, Gosia Sylwestrzak, Christine Shah, & Andrea DeVries,
Price transparency for MRIs increased use of less cost…
IRCCourt RulingsDec 18, 2012
…tioners' responsibility to file timely Federal income
tax returns on behalf of themselves, see sec. 1398 (providing that an individual
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
nder section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
ADMINISTRATIVE
Rev. Proc. 2006-34 Rev. Proc. 2006-34 This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure …
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
IRCProposed Rules (FR)Proposed Oct 15, 2007
…ermine liabilities under section 430(h)(3), were issued May 29, 2007 (REG-143601-06, 2007-24 I.R.B. 1398 [72 FR 29456]).
PBGCCode / StatuteJan 4, 1995
Notwithstanding any other provision of this part, an employer shall not be considered to have withdrawn from a plan solely because— For purposes of this part, a successor or parent corporation or other entity resulting from any such change shall be considered the original employer.
(1) (1) an employer ceases to exist b…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCFinal Rules (FR)Jun 24, 2011
…idual under either chapter 7 or 11 is a separate taxable entity for title 26 purposes.
See26 U.S.C. 1398. Although fiduciaries of these individual bankruptcy estates (trustees or debtors-in-possession) may be required to file Forms 1041, the bankruptcy estates are not pass-through entities as described in these regulat…
IRCCourt RulingsFeb 18, 1955
… circumstances surrounding the case. Lowell Wool By-Prod. Co. v. War Cont. Price Adj. Bd., 14 T. C. 1398. As we have found, Edward P. and Carolyn Haas owned 95 per cent of Haas Mold Company #1, together with 242 of the 308 outstanding shares of Metal Parts Corporation. Consideration of these and the other facts present…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJan 13, 1958
…ee of control over them. Lowell Wool By-Prod. Co. v. War Contracts Price Adjustment Board, 14 T. C. 1398 (1950), affd. 192 F. 2d 405 (C. A., D. C. 1951); Hug Co. v. War Contracts Price Adjustment Board, supra. Though equal partners, they participated in Zenith only to the extent of maMng a small contribution to capital…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsMar 24, 1959
…d to do otherwise on this record. Cf. Lowell Wool By-Prod. Co. v. War Cont. Price Adj. Bd., 14 T.C. 1398 (1950). Thus, at least 82 per cent of the corporation’s stock was held by petitioner’s partners or those directly related to them. Moreover, both petitioner’s managing partners served in an executive capacity with t…
Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect… IRCRevenue RulingsJun 23, 2014related by meaning
d restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.
Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.
Not…
IRCCourt RulingsJan 9, 1985related by meaning
section 4975 as follows:
(c) Effective Date and Savings Provisions.—
(1)(A) The amendments made by this section shall take effect on January 1, 1975. (B) If, before the amendments made by this section take effect, an organization described in section 401(a) of the internal Revenue Code of 1954 is denied exemption unde…
REG-139236-07 — Proposed regulations under section 430 of the Code provide guidance on the valuation of plan assets and the determination of benefit liabilities for purposes o… IRCProposed Rules (FR)Proposed Mar 3, 2008
…ermine liabilities under section 430(h)(3), were issued May 29, 2007 (REG-143601-06, 2007-24 I.R.B. 1398 [72 FR 29456]), and proposed regulation §1.430(f)-1, relating to prefunding and funding standard carryover balances under section 430(f), was issued August 31, 2007 (REG-113891-07, 2007-42 I.R.B. 821 [72 FR 50544]).
Rev. Proc. 2008-62 — This document sets forth the procedure by which the sponsor of a defined benefit plan, other than a multiemployer plan, may request and obtain approval for the… IRCRevenue ProceduresOct 20, 2008
…SA published in the Federal Register on May 29, 2007, at 72 FR 29456 [REG-143601-06, 2007-24 I.R.B. 1398] (“proposed regulations”). Final regulations under § 430(h)(3)(C) were published in § 1.430(h)(3)-2 in the Federal Register on July 31, 2008, at 73 FR 44632 [T.D. 9419, 2008-40 I.R.B. 790] (“regulations” or “final r…