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Go to I.R.C. § 381 (not yet in the library — opens the official source)
80 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    …er ceases to exist as a result of a transaction in which there is no successor described in section 381(a) (for example, as a result of a section 331 liquidation), then any suspended section 987 loss that is not recognized after applying the loss-to-the-extent-of-gain rule cannot be recognized and is eliminated. This r…
  3. 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…
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    er 1 as determined under subsection (e) by substituting — (i) in paragraph (1)(A), “200 percent” for “150 percent” . . . . 2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which all accuracy-related penalties are imposed on underpayments of tax. Section 6662(b) lists the penalizab…
  5. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …& Dana P. Goldman, Overpaying for Prescription Drugs: The Copay Clawback, (2018), https://schaeffer.usc.edu/​research/​overpaying-for-prescription-drugs/​.) Back to Citation 183.  Megan Thompson (2018), W hy a Patient Paid a $285 Copay for a $40 Drug, https://www.pbs.org/​newshour/​health/​why-a-patient-paid-a-285-copa…
  6. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …5)(ii)(B) provides that, immediately before an inbound or outbound transaction described in section 381(a), any unrecognized pretransition gain is recognized and any unrecognized pretransition loss is suspended. As a result, the suspended section 987 loss may be recognized, subject to the loss-to-the-extent-of-gain-rul…
  7. Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions
    IRCNoticesAug 24, 2026
    …rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
  8. 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…
  9. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsOct 15, 1999
    ded by § 381(c)(2) and § 1.381(c)(2)-1, Company will succeed to and take into account the earnings and profits, or deficit in earnings and profits, of Mutual as of the Closing Date. Any deficit in earnings and profits of either Mutual or Company will be used only to offset the earnings and profits accumulated after the…
  10. 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…
  11. 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…
  12. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  13. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …dual retirement annuity described in section 408(b). 6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
  14. 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…
  15. 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 …
  16. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tinued...) - 5 - of the Secretary, and in the same manner as taxes. Sec. 6652(c) (4) (A). Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect the tax by levy upon the property belonging to the person, subject to …
  17. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
  18. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    … One) 811 $152,127 Review & Update Notice (Subsequent Years) 406 76,064 Mail Disclosure (Annually) $381,544 First Year Total 811 152,127 381,544 Subsequent Year Total 406 76,064 381,544 Three-Year Average Total 541 101,418 381,544 Overall Summary The paperwork burden associated with the proposed rule is presented in Ta…
  19. Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex…
    IRCNoticesNov 13, 2007related by meaning
    g whether an estate making the section 6166 election will be required to provide security. TAX CONVENTIONS Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…
  20. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    ies as taxpayers who are living abroad. Johnny C. Finch, United States Citizens Living in Foreign Countries and Not Filing Federal Income Tax Returns, United States General Accounting Office, May 8, 1985. In addition, enforcement of compliance by individuals receiving mail at an APO, FPO, or DPO address generally does …