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82 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. 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…
  4. 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…
  5. 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…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  7. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    ensation may not avoid taxation by anticipatory arrangements regardless of their technical elegance. United States v. Basye, 410 U.S. 441, 450 (1973). In Armantrout v. Commissioner, 570 F.2d 210 (7th Cir. 1978), affg. per curiam 67 T.C. 996 (1977), an employer paid sums to a trustee who, in turn, paid school expenses f…
  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. 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…
  10. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  11. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  12. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…
  13. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    tz v. Commissioner , supra , and Kasey v. Commissioner , supra , is also misplaced. In those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and remitted to judgment creditors. In neither case is there any indication that the taxpayers disputed their …
  14. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  15. 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…
  16. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …s) Total annual burden (hours) Total estimated labor cost Total estimated cost 2022 4,059,610 4,103,368 1.1763434 4,826,970 $504,465,709 $784,429 2023 4,059,610 4,103,368 1.1763434 4,826,970 504,465,709 735,318 2024 4,059,610 4,103,368 1.1763434 4,826,970
  17. Treas. Reg. § 1.417(e)-1(d)(3)(ii)(A) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …17(e)(3) and this paragraph (d), the single-sum distribution received by P cannot be less than $250,368 (that is, $2,000 × 12 × 10.432).
  18. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
  19. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …fected by the proposed rule. 3.4. PBMs In 2023, there were 73 full-service PBMs in the marketplace.[368] These PBMs may also provide brokerage services to self-insured group health plans with respect to pharmacy benefit management services. PBMs fall under the NACIS Code 524292, or “Pharmacy Benefit Management and Othe…
  20. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    begin with section 4973. Section 4973 Section 4973(a) imposes a 6-percent excise tax on excess contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as a deduction under section 219 (computed without regard to section - 27 - 219(g)), exclusive of amounts p…