Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014
…uired to be operated in a manner that reflects the outcome of Windsor and the guidance in Rev. Rul. 2013–17? A–2. Qualified retirement plan operations must reflect the outcome of Windsor as of June 26, 2013. A retirement plan will not be treated as failing to meet the requirements of section 401(a) merely because it di…
IRCCourt RulingsFeb 9, 2023related by meaning
1984) ( stating that when comments
“brought to the attention of the agency nothing which it had not already
considered”, the agency need not respond). 2. T
hat s ome foreign legal restrictions apply only to
payments between related parties
Second, petitioner points out that two commentators explained
that some foreign …
Rev. Proc. 2015-27 — This revenue procedure contains modifications to Revenue Procedure 2013–12, 2013–4 I.R.B. 313. The modifications reflected in this revenue procedure include mi… IRCRevenue ProceduresApr 20, 2015
…nt benefits on a tax-favored basis. The most recent restatement of EPCRS is set forth in Rev. Proc. 2013–12, 2013–4 I.R.B. 313. The modifications to Rev. Proc. 2013–12 reflected in this revenue procedure include miscellaneous changes made to improve EPCRS, such as reducing VCP compliance fees relating to failures to me…
IRCCourt RulingsJun 25, 2013related by meaning
n.
- 15 -
To give effect to our disposition of the disputed issue, as well as
petitioner's concession, see sap_rg note 2,
Decision will be entered for respondent as to the income tax
deficiency and for petitioner as to the
accuracy-related penalty.
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
2013. The Final Rule was published in the
Federal Register
on February 13, 2013, and is effective on January 18, 2014.
See78 FR 10368 (Feb. 13, 2013). The preamble to the January 2013 Final Rule stated that the Agencies would consider exemptions for three additional types of transactions that commenters requested the A…
Notice 2013-58 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in September 2013; the 24-month average segment rat… IRCNoticesSep 30, 2013
…ding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from August 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of August 2013 are, respectively, 1.36, 4.60, and 5.58. For plan years beginning on or after January 1, 201…
IRCCourt RulingsSep 17, 2026related by meaning
…cord before the Court was
inconsistent with the reasons set forth in the denial and did not support
summary judgment. W e have denied petitioner’s motion to compel
production of documents and now will grant the Commissioner’s motion
and sustain the IRS’s determination.
Background
The following facts are derived from th…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
Ann. 2013-15 — This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to … IRCAnnouncementsMar 11, 2013
Announcement 2013-15
This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to include the correct addresses for submitting applications for determination letters and comments submitted by interested parties, in accorda…
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …
Notice 2013-23 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesApr 15, 2013
…e to the delayed publication of some IRS forms relating to the 2012 tax year.
EMPLOYEE PLANS
Notice 2013-23 Notice 2013-23 Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for pla…
IRCCourt RulingsJan 29, 2019related by meaning
made by the parties and, to the
extent they are not addressed herein, we find them to be moot, irrelevant, or
without merit.
To reflect the foregoing, Decision will be entered under
Rule 155.
Notice 2013-66 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in October 2013; the 24-month average segment rates… IRCNoticesNov 12, 2013
…g target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from September 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of September 2013 are, respectively, 1.40, 4.66, and 5.62. For plan years beginning on or after January 1, …
Notice 2013-75 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesDec 2, 2013
…ing target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from October 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of October 2013 are, respectively, 1.24, 4.47, and 5.52. For plan years beginning on or after January 1, 20…
Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect… IRCRevenue RulingsJun 23, 2014related by meaning
d restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.
Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.
Not…
Notice 2013-85 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in December 2013; the 24-month average segment rate… IRCNoticesDec 23, 2013
…ng target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from November 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of November 2013 are, respectively, 1.19, 4.53, and 5.66. For plan years beginning on or after January 1, 2…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
the Code. Both sections 18 and 19 describe generally the effect of §7805(b) relief.
Generally applied retroactively to modify or revoke prior TAM
.03 A holding that modifies or revokes a holding in a prior TAM is applied retroactively, with one exception. If the new holding is less favorable to the taxpayer than the e…
Notice 2014-48 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2014 used under § 417(e)(3)(D), the 24-… IRCNoticesSep 2, 2014
…ctions, and transition issues.
EFFECT ON OTHER DOCUMENTS
The following Notices are modified:
Notice 2013–11, 2013–11 I.R.B. 610,
Notice 2013–23, 2013–16 I.R.B. 906,
Notice 2013–28, 2013–19 I.R.B. 1039,
Notice 2013–32, 2013–22 I.R.B. 1137,
Notice 2013–37, 2013–26 I.R.B. 1269,
Notice 2013–46, 2013–31 I.R.B. 117,
Notice 2…
Ann. 2013-13 — This announcement contains corrections to Revenue Procedure 2013-6, 2013-1 I.R.B. 198, as published on January 2, 2013. In particular, this announcement clarif… IRCAnnouncementsFeb 25, 2013
Announcement 2013-13
This announcement contains corrections to Revenue Procedure 2013-6, as published on January 2, 2013 (2013-1 I.R.B. 198). In particular, this announcement clarifies that applications for determination letters should continue to be submitted to the Covington, KY address in section 6.15 of Rev. Proc. …
IRCCourt RulingsMay 22, 2025related by meaning
Treas. Reg. § 1.482-7T(i)(6) does
not operate as a safe harbor and therefore does not
preclude R from making a PCT allocation under paragraph
(i)(3). 6. Held, further, R did not abuse his discretion under
I.R.C. § 482 by adjusting P’s and S’s RAB shares to
determine the required CST p ayment.
7. Held, further, R ’s me…