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
, as defined in 12 CFR 252.61, or that is
pari passu
or subordinated to any eligible debt security issued by the global systemically important BHC; or (2) Issued by a Covered IHC, as defined in 12 CFR 252.161, and that is an eligible Covered IHC debt security, as defined in 12 CFR 252.161, or that is
pari passu
or subo…
IRCCourt RulingsFeb 22, 1989★ strong match
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
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
2017); 12 CFR part 252, subparts G and P. The TLAC rule's TLAC and long-term debt requirements took effect on January 1, 2019.
Back to Citation
12.
See 12 CFR 252.62 and 252.63; 12 CFR 252.162 and 252.165. The requirements applicable under the TLAC rule to covered BHCs and covered IHCs are similar but not identical.…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…nt for global systemically important banks issued by the BCBS, as updated from time to time. 12 CFR 252.2.
Back to Citation
70.
See 12 CFR 252.82(b) (definition of “covered entity” with regard to restrictions on qualified financial contracts); 12 CFR 252.160 (definition of “covered IHC” with regard to total loss-abso…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
aning as in 12 CFR 252.2.
* * * * *
Call Report
means the Consolidated Reports of Condition and Income.
Category II FDIC-supervised institution
means: (1) An FDIC-supervised institution that is a consolidated subsidiary of a company that is identified as a Category II banking organization pursuant to 12 CFR 252.5 or 12…
IRCCourt RulingsFeb 9, 2023related by meaning
TRW also
opposed the “both controlled and uncontrolled” clause, arguing that it
was inconsist ent with the Sixth Circuit opinion in Procter & Gamble . Two commentators -- the American Petroleum Institute and
TRW --- questioned the requirement of sec tion 1.482- 1T(f)(2)(ii)(D),
Proposed Income Tax Regs., 58 Fed. Reg. 5…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsAug 30, 1993related by meaning
least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMay 25, 2005related by meaning
…ences are viewed in a light most favorable to the nonmoving
party. Craig v. Commissioner
, 119 T.C. 252, 260 (2002);
Dahlstrom v. Commissioner
, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner
, 79 T.C. 340, 344 (1982). The party opposing
summary judgment must set forth specific facts which show that a
question of gen…
IRCCourt RulingsMar 27, 1989related by meaning
oyee contributions (whether voluntary or mandatory), to the extent that the return would reduce the excess amounts in the participant’s account. * * * The Commissioner is required to abide by regulations reasonably based on statute, and his failure to do so will amount to an abuse of discretion. Lansons, Inc. v. Commis…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsJan 3, 2011related by meaning
…would be the' hypotlietical' donorain' thé scehario posited by
petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention
sec tion 102 (a) , which exc ludes f rom- gros s income the value of
property acquired by Égift However, fori reasons discessed …
IRCCourt RulingsJul 24, 1984related by meaning
rectly involved in such ruling. * * *”
See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …