Proportionate nonliquidating distribution examples

Are amounts paid to an employee under a reimbursement plan that provides for the payment of unused reimbursement amounts in cash or other benefits excludable from gross income under § 105(b) of the Internal Revenue Code (the Code)?Employer sponsors a reimbursement plan (the Plan) that reimburses an employee solely for medical care expenses (as defined in § 213(d)) that are substantiated before the reimbursements are made.The Plan is paid for solely by Employer and is not provided pursuant to a salary-reduction election or otherwise under a § 125 cafeteria plan.The Plan provides reimbursements up to an annual maximum dollar amount for the coverage period, which is the plan year. This notice also provides interim procedures for electing investment partnerships and their partners to comply with sections 743(e) and 6031(f). In addition, these regulations would provide guidance under section 411 of the American Jobs Creation Act of 2004. This notice provides interim procedures for partnerships and their partners to comply with the mandatory basis adjustment provisions of sections 734 and 743 of the Code.The last Bulletin for each month includes a cumulative index for the matters published during the preceding months.These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.

This document does not provide guidance regarding the application of the arm’s length standard; rather, it reports on the structure and activities of the APA program. This procedure provides a safe harbor procedure under which the Service will disregard a spousal right of election for purposes of determining whether the CRAT or CRUT meets the requirements of section 664(d)(1)(B) or (d)(2)(B) of the Code continuously since its creation if the spouse irrevocably waives the right of election in the manner prescribed.

Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling.

The Plan satisfies the nondiscrimination requirements of § 105(h) for a self-insured medical expense reimbursement plan.

, except the Plan provides that the employee will receive a cash payment equal to all or a portion of the unused reimbursement amount available to that employee at the end of the plan year or upon termination of employment, if earlier.

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