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Securities and Exchange Commission v. Raytheon Company et al

MOTION for Disbursement of Funds to Pay Tax Obligations

2 Cited authorities

  1. Section 468B - Special rules for designated settlement funds

    26 U.S.C. § 468B   Cited 124 times   6 Legal Analyses
    In § 468B(g) Congress (1) expressed its general policy to permit taxation of settlement funds not then taxed under the DSF regulations, (2) expressly directed the Secretary of the Treasury to promulgate regulations, and (3) limited the exercise of the Secretary's authority to "escrow accounts, settlement funds,... and similar funds." I.R.C. § 468B(g).

  2. Section 1.468B-1 - Qualified settlement funds

    26 C.F.R. § 1.468B-1   Cited 19 times

    (a)In general. A qualified settlement fund is a fund, account, or trust that satisfies the requirements of paragraph (c) of this section. (b)Coordination with other entity classifications. If a fund, account, or trust that is a qualified settlement fund could be classified as a trust within the meaning of § 301.7701-4 of this chapter, it is classified as a qualified settlement fund for all purposes of the Internal Revenue Code (Code). If a fund, account, or trust, organized as a trust under applicable