IRCRegulationsDec 30, 2016★ strong match
4.4975-6(c)(2) are met, notwithstanding the provisions of section 4975(d)(4) (relating to investments in bank deposits). However, section 4975(d)(6) does not provide an exemption for an act described in section 4975(c)(1)(F) (relating to fiduciaries receiving consideration for their own personal account from any party …
IRCCode / StatuteJan 6, 2025related by meaning
(d)(13) (13) any transaction which is exempt from section 406 of such Act by reason of section 408(e) of such Act (or which would be so exempt if such section 406 applied to such transaction) or which is exempt from section 406 of such Act by reason of section 408(b)(12) of such Act;
(d)(14) (14) any transaction requir…
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…
IRCCourt RulingsJan 27, 1998★ strong match
…abor (not the Secretary of the Treasury) can assess
a civil penalty (not the tax penalty under sec. 4975). The
second-tier tax of sec. 4975(b) applies if a prohibited
transaction is not corrected within the "taxable period", which
is defined under sec. 4975(f)(2). In this case, the taxable
period ended on the date of t…
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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
…rrahan Agency
Petitioners argue that the Garrahan Agency is not a
disqualified person under section 4975(e)(2)(G) because 50 percent or more of its voting stock was not owned by a
disqualified person described in section 4975(e)(2)(A), (B), (C),
(D), or (E). We disagree.
A disqualified person includes any corporation 5…
IRCCourt RulingsAug 13, 1990
ed persons or that the plan is not a plan within the coverage of section 4975. See sec. 4975(e)(1) and (2) (“plan” and “disqualified person” defined). The “taxable period” extends from the date of the prohibited transaction to the earlier of (1) the date respondent mails a statutory notice determining a deficiency in s…
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…
IRCRegulationsDec 30, 2016★ strong match
(a) (a) [Reserved]
IRCCourt RulingsJan 9, 1985★ strong match
…ailroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To reflect stipulations by the parties,
Decision will be entered under Rule 155.
Unless otherwise indicated, a…
IRCCourt RulingsJun 1, 1987
…syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited transaction which is to be paid by any “disqualified person…
IRCCourt RulingsMay 27, 2004
s of stock is owned by a
person described in sec. 4975(e)(2)(A) or (E). Thus, by virtue
of its ownership by petitioner, Inland also was a disqualified person as to the second and third loans. The possibility that
Inland may be liable for excise taxes under sec. 4975(a) or (b)
as to the second and third loans is unimpor…
IRCCourt RulingsNov 15, 2004★ strong match
…in table.1, was a
loan. Respondent does not contend that any of the transactions
fits under section 4975(c)(1)(B) ("any direct or indirect--(B)
lending of money or other extension of credit between a plan and
a disqualified person"), but focuses only on subparagraphs (D)
and (E) of section 4975(c)(1). We consider first…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
r sections 1445 and 1446 for dispositions of USRPIs by foreign pension funds and their subsidiaries.
II. Taxation of Foreign Persons Under Section 897 Section 897(a)(1) provides that gain or loss of a nonresident alien individual or foreign corporation from the disposition of a USRPI is taken into account under section…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]