This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether income is effectively connected with the conduct of a trade or business within such a U.S. possession or territory.
Rev. Proc. 2006-37(HTML)
This procedure modifies Rev. Proc. 2006-12, 2006-3 I.R.B. 310, to allow a taxpayer to utilize the advance consent procedures of Rev. Proc. 97-27, as modified and amplified by Rev. Proc. 2002-19, as amplified and clarified by Rev. Proc. 2002-54, when seeking a change to a method of accounting provided in regulations sections 1.263(a)-4, 1.263(a)-5, or 1.167(a)-3(b) in conjunction with a change for the same item to a method of accounting utilizing the 31/2 month rule authorized by regulations section 1.461-4(d)(6)(ii) or the recurring item exception authorized by regulations section 1.461-5. Rev. Proc. 2006-12 modified.
Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
Rev. Proc. 2006-34(HTML)
This procedure provides specifications for filing Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure will be reproduced as the current revision of Publication 1187. Rev. Proc. 2004-63 superseded.
Rev. Proc. 2006-36(HTML)
This procedure sets forth the Service's procedures for other government agencies or members of the public to request the creation of special statistical studies and compilations involving return information pursuant to section 6108(b) of the Code, and sets forth the criteria for determining reasonable fees for costs associated with the creation of the special statistical studies and compilations.
This document contains corrections to temporary regulations (T.D. 9260, 2006-23 I.R.B. 1001) that relate to the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations under section 904(d)(4).
This document contains corrections to final regulations (T.D. 9272, 2006-35 I.R.B. 332) that relate to income that is associated with a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) and that is allocated through certain entities to foreign persons who have invested in those entities.
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