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