Chapter c 4 corporate nonliquidating distributions
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.It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin.All published rulings apply retroactively unless otherwise indicated.The Plan reimburses medical care expenses only to the extent that the employee or the employee’s spouse or dependents have not been reimbursed for the expense from any other plan.Under the Plan, a portion of each employee’s reimbursement amount available at the end of each plan year is forfeited if not used to reimburse medical expenses.This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2004. 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.
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. 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.It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis.Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis.