88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
ation
133.
Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)(
5), 29 CFR 2590.716-8(b)(2)(ii)(A)(
5), and 45 CFR 149.510(b)(2)(ii)(A)(
5).
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134. Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
mission of additional information from the disputing parties at 26 CFR 54.9816-8(c)(2)(ii), 29 CFR 2590.716-8(c)(2)(ii), and 45 CFR 149.510(c)(2)(ii). To clarify and establish a standard process for disputes to be withdrawn from the Federal IDR process, the Departments are finalizing four conditions in which a dispute …
IRCPrivate Letter RulingsJun 22, 2001
an election
under section 936 applies, or (4) a DISC or former DISC.
Section 1361(b)(3)(A) provides that except as provided in regulations prescribed by the Secretary, for purposes of title 26 (i) a corporation which is a qualified
subchapter S subsidiary shall not be treated as a separate corporation, and (ii) all
as…
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, 2024
…standing shares of stock confer identical rights to distribution and liquidation proceeds under § 1.1361-1(l)(2), whether a principal purpose of a commercial contractual agreement, a buy-sell agreement, an agreement restricting the transferability of stock, or a redemption agreement is to circumvent the one class of st…
86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCFinal Rules (FR)Jan 6, 2021
2 (FDIC) (“synthetic exposure”).
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32.
See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”).
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33.
See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC).
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88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
15-2715A1(a)(2)(xx), 29 CFR 2590.715-2715A1(a)(2)(xix), 45 CFR 147.210(a)(2)(xx).
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170.
29 CFR 2520.102-2(a).
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171.
See 26 CFR 54.9815-2715(a)(4)(ii)(B), 29 CFR 2590.715-2715(a)(4)(ii)(B), 45 CFR 147.200(a)(4)(ii)(B).
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172.
26 CFR 54.9815-2719, 29 CFR 2590.715-2719, a…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…n 408(a) of th
e
Internal Revenue Code a permitted shareholder . of an .S corporation
under section 1361? "
The ruling reviewed'Code section 1361(c)(2)(A)(i) and
1361(d)(l) .and reasoned :
A section 408(a) trust
cannot also be a trust described in
section 1361(c)(2)(A)(i) or a QSST treated as a trust described in secti…
84 FR 13814 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCProposed Rules (FR)Proposed Apr 8, 2019
sheet exposures.
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3.
See 12 CFR 3.22(c)(1) (OCC); 12 CFR 217.22(c)(1) (Board); and 12 CFR 324.22(c)(1) (FDIC).
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4.
See 12 CFR 3.22(c)(2) (OCC); 12 CFR 217.22(c)(2) (Board); and 12 CFR 324.22(c)(2) (FDIC).
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5.
See 12 CFR 3.22(c)(3) through (5) (OCC); 12 CFR 217.22(c)…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
90 FR 23303 — Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule IRCProposed Rules (FR)Proposed Jun 2, 2025
.210(a)(2)(xi).
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20.
26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D).
21. The TiC final rules also clarify that nothing in 26 CFR 54.9815-2715A3(b)(1)(iii)(D), 29 CFR 2590.715-2715A3(b)(1)(iii)(D), and 45 CFR 147.212(b)(1)(iii)(D) requires th…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
Rev. Rul. 2004-4 — Employee stock ownership plans; S corporations; listed transactions. A finding of synthetic equity owned by a disqualified person in a nonallocation year of an… IRCRevenue RulingsFeb 9, 2004
…)(7), additional requirements are imposed under § 54.4975-11 of the Excise Tax Regulations. Section 1361(b)(1)(B) provides that an S corporation may not have as a shareholder a person that is not an estate, a trust described in § 1361(c)(2), an organization described in § 1361(c)(6), or an individual. In 1996, § 1361(c…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCPrivate Letter RulingsJul 13, 2018
… under the laws of Sta te C and has elected to be taxed as a subchapter S corporation under section 1361 of the Internal Revenue Code (Code).
In ------- , Company A established ESOP A, and it continues to maintain ESOP A for its
employees. ESOP A is qualified plan under sec tion 401(a) and an ESOP under section
4975(e)…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
… does not meet the requirements of section 5.02 of Rev. Proc. 2003-14, 2003-1 C.B. 319.
.05 Section 1361.—Definition of a Small Business Corporation.—Whether a state law limited partnership electing under § 301.7701-3 to be classified as an association taxable as a corporation has more than one class of stock for purpo…