IRCCourt RulingsJul 31, 2000
…o him
because Marlton is not a corporation.
As to Ms. Lo, she was a Marlton employee. Under section
264(a)(1), however, a taxpayer may not deduct life insurance
premiums to the extent that the taxpayer is “directly or
indirectly a beneficiary” of the underlying policy.
34
Sec.
264(a)(1). Respondent argues that section …
IRCCourt RulingsMar 4, 1999
…purchase or carry” single
premium life insurance or endowment contracts, within the meaning
of sec. 264(a)(2). Moreover, the exception contained in sec.
264(c)(3) pertains only to plans referred to in sec. 264(a)(3),
which specifically excludes single premium contracts.
section 264(a)(2) nor the cited exception applies…
ERISACode / StatuteJan 6, 2025related by meaning
(c) (c) Statement of rights The Secretary may by regulation require that the administrator of any employee benefit plan furnish to each participant and to each beneficiary receiving benefits under the plan a statement of the rights of participants and beneficiaries under this subchapter.
PBGCCode / StatuteJan 6, 2017related by meaning
(b)(2)(B)(iii) (iii) the reason for any change in the determination of the employer's liability or schedule of liability payments.
PBGCCode / StatuteJan 6, 2025related by meaning
(c) (c) Adjudication that plan must be terminated
ERISACode / StatuteJan 6, 2025related by meaning
(b)(5) (5) to a contract established and maintained under section 403(b) of title 26 to the extent that the assets of the contract are held in one or more custodial accounts pursuant to section 403(b)(7) of title 26.
(b)(6) (6) Any plan, fund or program under which an employer, all of whose stock is directly or indirec…
IRCPrivate Letter RulingsApr 22, 2016
… purposes o f sections 72(e)(4), 72(e)(5),72(e)(10),
72(e)(12), 72(q), 72(s), 72(u), 72(v), 101(f), 264(a)(2), 264(a)(3), 264(a)(4), 264(c),
264(f), 7702, and 7702A; and
2. The proposed merger also will not require retesting or the start of a new
test period under se ctions 264(d)(1), 7702(f)(7)(B) - (E), and 7702A(c).…
PBGCCode / StatuteJan 5, 2015related by meaning
§§1421 to 1425. Repealed. Pub. L. 113–235, div. O, title I, §108(a)(1), Dec. 16, 2014, 128 Stat. 2786
PLR 200711014 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsMar 16, 2007
…ontracts
was issued after June 8, 1997.
Issue 1
The first issue involves the application of section 264(f)(4)(A) to the New Contracts.
Section 264(f)(1) states that no deduction shall be allowed for that portion of the
taxpayer's interest expense that is allocable to unborrowed policy cash values.
However, section 264(…
ERISACode / StatuteJan 24, 2020related by meaning
(c) (c) Individual statement furnished by administrator to participants setting forth information in administrator's Internal Revenue registration statement and notification of forfeitable benefits Each administrator required to register under section 6057 of title 26 shall, before the expiration of the time prescribed…
ERISACode / StatuteJan 6, 2025related by meaning
(a) (a) Requisite bonding of plan officials Every fiduciary of an employee benefit plan and every person who handles funds or other property of such a plan (hereafter in this section referred to as "plan official") shall be bonded as provided in this section; except that—
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
tment in a building” under § 216(b)(1)(B).
(45) Section 264.—Certain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(d)(1) applies. (46) Section 264(c)(1).—Contracts Treated as Single Premium Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 …
PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable) IRCPrivate Letter RulingsApr 23, 1999
…ce for
purposes of §§ 72(e)(4), 72(e)(5), 72(e)(10), 72(e)(11), 72(q), 72(s), 72(u), 72(v), 101(f),
264(a)(1), 264(a)(3), 264(a)(4), 264(f), 7702 and 7702A of the Code. Moreover, the conversion
will not require retesting or the starting of new test periods for the contracts §§ 264(c)(1),
7702(f)(7)(B)-(E), and 7702A(c)…
ERISACode / StatuteJan 6, 2025related by meaning
(m) (m) Penalty for improper distribution In the case of a distribution to a pension plan participant or beneficiary in violation of section 1056(e) of this title by a plan fiduciary, the Secretary shall assess a penalty against such fiduciary in an amount equal to the value of the distribution. Such penalty shall not …
Rev. Rul. 2007-65 — Employer’s deduction for contributions; limitation on employer’s deduction; welfare benefit funds. This ruling discusses whether an employer’s deductions for c… IRCRevenue RulingsNov 5, 2007
…n deductible under § 263 if made directly by the employer. Q&A-6(c) of § 1.419-1T also refers to §§ 264 and 274. In its explanation of “qualified direct cost,” the legislative history of § 419 states that the rules in other Code sections that generally limit deductions if an employer provides the plan benefits directly…
ERISADOL Technical ReleasesJun 17, 2026related by meaning
…e whole law, and to its object and policy” in deciding what type of benefit programs are covered by ERISA). ↩ See FAB 2004-01 (April 7, 2004) and FAB 2006-02 (October 27, 2006) which came to similar conclusions regarding employers’ involvement with Health Savings Accounts. ↩
29 C.F.R. 2510.3-2(d)(1)(iii). ↩
See Interpr…
PLR 200208017 — Taxation of Employee Annuities (Taxable v. Not Taxable) IRCPrivate Letter RulingsFeb 22, 2002
… purposes of sections 72(e)(4), 72(e)(5), 72(e)(10), 72(e)(11), 72(q),
72(s), 72(u), 72(v), 101(f), 264(a)(3), 264(a)(4), 264(f), 7702, and 7702A.
Moreover, the Reorganization will not require retesting or the starting of new test
periods for the contracts under sections 264(d)(1), 7702(f)(7)(B)-(E), and
7702A(c)(3)(A)…
90 FR 28004 — Removal of Interpretive Bulletins Relating to the Employee Retirement Income Security Act of 1974 ERISAFinal Rules (FR)Jul 1, 2025related by meaning
…TARY INFORMATION:
I. Background and Discussion The Employee Retirement Income Security Act of 1974 (ERISA) is a comprehensive Federal law that sets minimum standards for most voluntarily established employee benefit plans in private industry. Title I of ERISA protects the interests of participants and their beneficiari…
76 FR 76222 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities ERISAProposed Rules (FR)Proposed Dec 6, 2011related by meaning
…
—(1)
Civil penalties and procedures.
For information on civil penalties under section 502(c)(5) of ERISA for persons who fail to file the information required under this section, see § 2560.502c-5. For information relating to administrative hearings and appeals in connection with the assessment of civil penalties unde…
PBGCPBGC Opinion LettersAug 2, 1994
…he 20-year cap li mitat ion, r egardles s of when [*5] t he employer
wi th draw s f rom t he pl an. ERISA §
4219(c)(1)(D );
29
C.F. R.
§ 2648.3(b)(1). Under ERISA § 4219(c)(1)(D)(ii ) and 29 C.F.R. § 2648.3(c), an employer
is
subject to the f ull all ocation of the
plan' s unf unded vest ed benefi ts onl y if the emplo…