In Rev. Rul.
2015-10, the IRS extended the principles of Rev.
Second, Rev. Rul.
69-136 does not answer the question whether a guarantee of reemployment (either by the employer or by law) or the provision of more protections and rights than required by law changes the ruling's conclusion that the differential payments are not subject to Federal payroll taxes.
338 and the ruling history, Rev. Rul.
2008-25 held that the transaction is not stepped together to cause an acquisition but instead represents a QSP followed by a liquidation.
2002-22 specifically states that the assignment of income doctrine [see Lucas v.
The Preamble does not warn employers, however, that Rev. Rul.
99-7 changed the definition of temporary work location to import the one-year rule from section 162(a) of the Code, resulting in a standard more confusing to apply than the previous standard that a temporary work location was any location at which the taxpayer performed services on an irregular or short-term basis, such as a matter of days or weeks.
Although Rev. Rul.
2008-18 addresses two common transactions, there are other permutations of F reorganizations for which additional guidance would be helpful.
The Journal article notwithstanding, the issuance of Rev. Rul.
96-62 is a good thing.
83 regulations to explicitly set forth the holdings in Rev. Rul.
200548, but no amendments have been finalized yet.
88-57 provides guidance concerning the treatment of the repairs conducted pursuant to a program for major cyclical rehabilitation following a predetermined period of use in the taxpayer's business.(20) That ruling, together with the plan-of-rehabilitation doctrine,(21) was cited in a recent technical advice memorandum to require capitalization of routine aircraft engine inspections and overhauls.(22) In addition, the plan-of-rehabilitation doctrine has been cited by agents to deny deductions for the costs of removing equipment (costs of removal) pursuant to a "plan" to install new equipment.
93-72 does not explain the term "substantially beyond," but does appear to acknowledge that the concepts behind the 1975 rulings are applicable to other types of medical expenses (such as tuition and fees paid to special schools).
In Rev. Rul.
67-125,(3) the Internal Revenue Service held that legal fees for advice on the tax significance of a potential reorganization must be capitalized.
In Rev. Rul.
76-395, 1976-2 CB 16, the Service ruled that payments made to low-income individuals primarily to subsidize home improvements necessary to correct building code violations and provide safe and decent housing were excluded from the recipients' income under the GWE.