Internal Revenue Bulletins  
November 20, 2006

Internal Revenue Bulletin No. 2006-47

Official IRS Bulletin Documents linked below are in HTML: Revenue Rulings, Revenue Procedures, Announcements, Notices, Treasury Decisions, Regulations, Treaties, etc.
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Rev. Rul. 2006-57(HTML)
Qualified transportation fringes; smartcards and debit cards. This ruling provides guidance to employers on the use of smartcards and debit cards to provide qualified transportation fringes under section 132(f) of the Code.

T.D. 9292(HTML)
Final regulations under section 704 of the Code provide that allocations of creditable foreign tax expenditures cannot have substantial economic effect, and, therefore, must be allocated in accordance with the partners' interests in the partnership. The regulations provide a safe harbor whereby allocations of creditable foreign tax expenditures will be deemed to be in accordance with the partners' interests in the partnership. To satisfy the safe harbor, allocations of creditable foreign tax expenditures must be in proportion to the distributive shares of income to which the taxes relate.

Proposed regulations under section 72 of the Code provide guidance on taxation of the exchange of property for an annuity contract. The regulations would apply the same rule to exchanges for both private annuities and commercial annuities, but the regulations would not affect charitable gift annuities. A public hearing is scheduled for February 16, 2007.

Proposed regulations under section 141 of the Code provide guidance relating to the standards for treating payments in lieu of taxes as generally applicable taxes for purposes of the private security or payment test. A public hearing is scheduled for February 13, 2007.

Notice 2006-101(HTML)
This notice updates Notice 2003-69, 2003-2 C.B. 851, which contains a list of the United States tax treaties that meet the requirements of section 1(h)(11)(C)(i)(II) of the Code. Notice 2003-69 amplified and superseded.

Rev. Proc. 2006-42(HTML)
This document provides rules for taxpayers to obtain automatic approval to change certain elections to apportion interest expense and research and experimentation expense under section 861 of the Code as a result of new rules under the section 199 domestic production activities deduction.

Rev. Proc. 2006-51(HTML)
This procedure amplifies Rev. Proc. 2005-70, 2005-47 I.R.B. 979, to provide the maximum amount of foreign earned income, as adjusted for inflation, that may be excluded from gross income under section 911 of the Code for taxable years beginning in 2006. Rev. Proc. 2005-70 amplified.


Notice 2006-103(HTML)
Because Patriots' Day falls on Monday, April 16, this notice provides individual taxpayers residing in Maine, Maryland, Massachusetts, New Hampshire, New York, Vermont, and the District of Columbia an additional day to file their federal income tax returns and make their payments (until April 17, 2007). The additional day applies to the payment of the first installment of estimated tax for 2007.

Rev. Proc. 2006-48(HTML)
Guidance is provided concerning when information shown on a return in accordance with the applicable forms and instructions will be adequate disclosure for purposes of reducing an understatement of income tax under sections 6662(d) and 6694(a) of the Code.

Rev. Proc. 2006-49(HTML)
Optional standard mileage rates. This procedure announces 48.5 cents as the optional rate for deducting or accounting for expenses for business use of an automobile, 14 cents as the optional rate for use of an automobile as a charitable contribution, and 20 cents as the optional rate for use of an automobile as a medical or moving expense for 2007. The procedure also provides rules for substantiating the deductible expenses of using an automobile for business, moving, medical, or charitable purposes. Rev. Proc. 2005-78 superseded.

Rev. Proc. 2006-50(HTML)
Substantiation of expenses of Native Alaskan whaling captains. This document provides the procedures for the substantiation of whaling expenses of an individual recognized as a whaling captain by the Alaska Eskimo Whaling Commission.

Announcement 2006-90(HTML)
This document contains corrections to a notice of proposed rulemaking (REG-124152-06, 2006-36 I.R.B. 368) and notice of public hearing relating to the determination of who is considered to pay a foreign tax for purposes of sections 901 and 903 of the Code.

Announcement 2006-91(HTML)
This document contains corrections to final and temporary regulations (T.D. 9244, 2006-8 I.R.B. 463) under sections 358 and 1502 of the Code regarding the determination of the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions.

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