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79 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. PLR 200208017 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsFeb 22, 2002
    …stock for Mutual Holding membership interests will constitute a reorganization described in section 368(a)(1)(B). 8. The Company Members will recognize no gain or loss on the deemed exchange of their Company stock for Mutual Holding membership interests (section 354(a)(1)). 9. The basis of the Mutual Holding membership…
  2. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …8 Benefits 526 8.7 62 4,576 285,235 Legal 526 1.1 130 572 74,329 Sub-Total 11,441 888,052 Small: IT 368 7.8 84 2,884 242,244 Benefits 368 5.7 62 2,098 130,743 Legal 368 0.7 130 262 34,070 Sub-Total 5,244 407,058 Total 54,750 4,249,887 Table 8—Update SBC Including Coverage Examples, Subsequent Years Type of labor Number…
  3. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …   See Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​05/​03/​provider-charges-relative-to-medicare-rates-2012-2018/​. Back to Citation 210…
  4. Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c…
    IRCNoticesMay 6, 2024
    … and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
  5. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsOct 15, 1999
    … Prior to Mutual’s transfer to Company, Group will be in control of Company within the meaning of § 368(c). (c) Following Mutual’s transfer to Company, Company has no plan or intention to issue additional shares of its stock that would result in Group losing control of Company within the meaning of § 368(c). (d) Mutual…
  6. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  7. Notice 2024-16 — Guidance Related to Section 961 and Certain Inbound Nonrecognition Transactions
    IRCNoticesJan 29, 2024
    …asset reorganization. A liquidation described in section 332, a reorganization described in section 368(a)(1)(A) (but not section 368(a)(2)(D) or 368(a)(2)(E)) (“nontriangular A reorganization”), or a reorganization described in section 368(a)(1)(C) (determined without regard to the parenthetical) (“nontriangular C reo…
  8. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010
    …rrender charge, the entire cash value of the insurance policy for purposes of section 402(a) was $1,368,327 .33--the same amount that respondent asserts as the policy's fair market value . A valuation of $1,368,327 .33 is strongly, supported by the fact that Hartford Life credited the trust with a $1,368,327 .33 premiu…
  9. 89 FR 84079 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCFinal Rules (FR)Oct 21, 2024related by meaning
    t to withholding under subchapter A of chapter 3 (sections 1441 through 1446 of the Code). 1. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the regulation treats an Army Post Office (APO), a Fleet Post Office (FPO), or a Diplomatic Post Office (DPO) [2] address as an a…
  10. 89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
    IRCFinal Rules (FR)Apr 3, 2024
    …hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2020/​08/​04/​fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
  11. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    atement for any taxable year, there shall be added to the tax an amount equal to 20% of the amount of such understatement." The penalty applies to any deficiency which is attributable to any listed transaction or any reportable transaction if a significant purpose of the transaction is the avoidance or evasion - 41 - o…
  12. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
  13. 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
    ection is applicable on July 6, 2007. § 54.6011-1T [Amended] Par. 10. Section § 54.6011-1T(c) & (d) are removed. PART 301—PROCEDURE AND ADMINISTRATION Par. 11. The authority citation for part 301 continues to read, in part, as follows: Authority: 26 U.S.C. 7805 * * * Par. 12. Section 301.6011(g)-1 is added to read as f…
  14. Rev. Proc. 2006-3 — 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, 2006
    …g shareholders includes an installment obligation of the purchasing entity. (33) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same Corpo…
  15. 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
    …g shareholders includes an installment obligation of the purchasing entity. (31) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same Corpo…
  16. 75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Jun 16, 2010related by meaning
    URE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * *. Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows: § 301.6404-0 Table of Contents. * * * * * § 301.6404-4 Suspension of interest and c…
  17. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  18. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003
    …Tax Regs. 5 Howard E. Clendenen, Inc. v. Commissioner , supra . Petitioners argue that Rev. Rul. 72-368, 1972-2 C.B. 220, and Rev. Rul. 73-79, 1973-1 C.B. 194, support their contention that disqualification in a prior year does not prevent the plan from being qualified in a future year when it meets the requirements of…
  19. T.C. Memo. 2016-110 — Kenneth L. Mallory & Larita K. Mallory v. Commissioner
    IRCCourt RulingsJun 6, 2016related by meaning
    racy-related penalty under section 6662(a) and (b)(2) for an underpayment due to a substantial understatement of income tax for the 2011 taxable year. Section 6662(a) imposes a 20% "accuracy-related penalty" on an underpayment of tax attributable to any of the causes listed in section 6662(b). These causes include "[a]…
  20. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    acted in good faith with respect to such portion. ” Unlike the reasonable cause and good faith exception found in section 6664(c), Congress placed the adequate disclosure exception in section 6662(d), with no text indicating that it was meant to apply to multiple section 6662 penalties. The reason for t his is apparent…