Internal Revenue Bulletins  
June 12, 2006

Internal Revenue Bulletin No. 2006-24

Official IRS Bulletin Documents linked below are in HTML. These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
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T.D. 9262(HTML)
Temporary and proposed regulations concern the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities, to certain transactions involving computer software. A public hearing on the proposed regulations is scheduled for August 29, 2006.

Proposed regulations under section 21 of the Code conform the rules relating to the child and dependent care credit to statutory changes including amendments under the Working Families Tax Relief Act of 2004, and address significant issues that have arisen administratively. The regulations are renumbered to conform to the renumbering of the statute.

Notice 2006-30(HTML)
This notice informs trustees and middlemen of non-mortgage widely held fixed investment trusts (NMWHFITs) that the date for satisfying the qualified NMWHFIT exception in regulations section 1.671-5(c)(2)(iv)(E) is extended by 60 days.

Notice 2006-46(HTML)
This notice announces that the IRS and Treasury intend to issue final regulations under sections 897(d) and (e) of the Code, which will revise the current rules under temporary regulations sections 1.897-5T and 1.897-6T and Notice 89-85, 1989-2 C.B. 403. When finalized, regulations will revise temporary regulations section 1.897-5T(c)(4) to take into account inbound statutory mergers and consolidations described in section 368(a)(1)(A). The regulations will also revise the rules of temporary regulations section 1.897-6T(b)(1) to take into account foreign-to-foreign statutory mergers and consolidations described in section 368(a)(1)(A) and to create two new exceptions to gain recognition under section 1.897-6(b)(1) for certain foreign-to-foreign asset reorganizations. The regulations will also revise the stock disposition rule of temporary regulations section 1.897-6T(b)(1)(iii) and eliminate the conditions specified for nonrecognition in temporary regulations section 1.897-6T(b)(2). Lastly, the regulations will modify the period that must be considered for imposing taxes and accrued interest on prior dispositions of the stock of foreign corporations. Notice 89-85 amplified.

Rev. Proc. 2006-21(HTML)
Section 1502. The Service eliminates impediments to e-filing consolidated returns and reduces reporting requirements. Rev. Procs. 89-56, 90-39, and 2002-32 modified.

Announcement 2006-35(HTML)
Insurance companies; interest rate tables. This announcement corrects an error in Rev. Rul. 2006-25, 2006-20 I.R.B. 882 (May 15, 2006).

Announcement 2006-38(HTML)
This document contains corrections to final regulations (T.D. 9243, 2006-8 I.R.B. 475) that amend the income tax regulations under various provisions of the Code to account for statutory mergers and consolidations.

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