2006 IRB Documents Providing Guidance for Tax Professionals

These are documents issued in IRS's weekly Internal Revenue Bulletin (IRB) that provide guidance to Tax Professionals.

Documents are either in HTML or in the Adobe Acrobat PDF format. Internal Revenue Bulletin Summary pages are in HTML format.

Document	Bulletin	Date of IRB


T.D. 9285(HTML)	IRB #2006-41(HTML)	October 10, 2006
Final regulations under section 448 of the Code provide rules relating to the use of a nonaccrual-experience method of accounting by taxpayers using an accrual method of accounting and performing services. The regulations affect qualifying taxpayers that want to adopt, change to, or change a nonaccrualexperience method of accounting under section 448(d)(5).
Notice 2006-86(HTML)	IRB #2006-41(HTML)	October 10, 2006
This notice provides interim guidance under section 152(c)(4) of the Code, the rule for determining which taxpayer may claim a qualifying child when two or more taxpayers claim the same child. It clarifies that, unless the special rule in section 152(e) applies, the tie-breaking rule in section 152(c)(4) applies to the head of household filing status, the child and dependent care credit, the child tax credit, the earned income credit, the exclusion for dependent care assistance, and the dependency deduction as a group, rather than on a section-by-section basis.
Notice 2006-78(HTML)	IRB #2006-41(HTML)	October 10, 2006
This notice announces the phase-out of the qualified hybrid motor vehicle credit and the new advanced lean burn technology motor vehicle credit for passenger automobiles and light trucks manufactured by Toyota Motor Corporation that are purchased for use or lease in the United States beginning on October 1, 2006.
Notice 2006-83(HTML)	IRB #2006-40(HTML)	October 2, 2006
This notice provides guidance to individual chapter 11 debtors and their bankruptcy estates regarding the tax treatment of post-petition income as the result of the enactment of section 1115 of the Bankruptcy Code by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. The notice also alerts information return preparers regarding their reporting responsibilities.
T.D. 9273(HTML)	IRB #2006-37(HTML)	Sept. 11, 2006
Final regulations under section 367 of the Code provide guidance with respect to the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a foreign-to-foreign or inbound corporate reorganization or liquidation described in both section 367(b) and section 381.
Announcement 2006-63(HTML)	IRB #2006-37(HTML)	Sept. 11, 2006
This announcement describes the limited role of private collection agencies (PCAs) in the collection of federal taxes. The announcement includes descriptions of the legal restrictions and administrative procedures in place to ensure PCAs respect taxpayer rights and protections. The announcement also describes what a taxpayer can expect if the IRS assigns the taxpayer's account to a PCA for collection activity.
Announcement 2006-61(HTML)	IRB #2006-36(HTML)	Sept. 5, 2006
This announcement provides an opportunity for small business/ self employed taxpayers to use Fast Track Settlement (FTS) to expedite case resolution within the IRS's Small Business/ Self Employed (SB/SE) organization. The SB/SE FTS will enable SB/SE taxpayers that currently have unagreed issues in at least one open year under examination to work together with SB/SE and the Office of Appeals to resolve outstanding disputed issues while the case is still in SB/SE jurisdiction.
Notice 2006-72(HTML)	IRB #2006-36(HTML)	Sept. 5, 2006
This notice contains questions and answers that provide guidance on the information reporting requirements for qualified tuition and related expenses under section 6050S of the Code.
Announcement 2006-52(HTML)	IRB #2006-33(HTML)	August 14, 2006
Change in accounting methods; revised instructions for Form 3115. The instructions for Form 3115 have been revised as of May 2006. The May 2006 version of the instructions for Form 3115 is to be used with the December 2003 version of Form 3115, Application for Change in Accounting Method.
T.D. 9277(HTML)	IRB #2006-33(HTML)	August 14, 2006
Final regulations under section 4980G of the Code provide guidance regarding employer comparable contributions to Health Savings Accounts (HSAs). The regulations provide that if an employer makes comparable contributions to any employee's HSA, the employer must make comparable contributions for the calendar year to the HSAs of all comparable participating employees. In addition, the final regulations set forth the rules for calculating comparable contributions.
T.D. 9270(HTML)	IRB #2006-33(HTML)	August 14, 2006
Final regulations under section 6045(f) of the Code relate to information reporting for payments of gross proceeds to attorneys. Regulations under section 6041 are also amended with respect to information reporting for payments for legal services.
Notice 2006-68(HTML)	IRB #2006-31(HTML)	July 31, 2006
This notice alerts taxpayers who submit offers in compromise on or after July 16, 2006, that they must include a nonrefundable down payment with their offers. The notice also waives the down payment requirement for low-income taxpayers and taxpayers who submit offers based solely on doubt as to liability. July 31, 2006 2006-31 I.R.B.
Rev. Proc 2006-30(HTML)	IRB #2006-31(HTML)	July 31, 2006
Report of tips by employee to employer. This procedure provides guidance on the Attributed Tip Income Program (ATIP), which is a new voluntary tip reporting program providing benefits to employers and employees similar to other tip reporting agreements without requiring one-on-one meetings with the Service to determine tip rates or eligibility. (Continued on the next page)
Notice 2006-63(HTML)	IRB #2006-29(HTML)	July 17, 2006
This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the notice seeks comments regarding any burdens associated with the record retention requirements that apply to issuers and other parties to tax-exempt bond transactions in order to substantiate compliance with section 103 of the Code. Comments should be received by October 16, 2006.
T.D. 9268(HTML)	IRB #2006-30(HTML)	July 24, 2006
Final, temporary, and proposed regulations provide guidance under sections 6038 and 6038A of the Code. The final regulations under section 1.6038-2 are revised to remove and replace obsolete references to a form and IRS offices. The regulations clarify the information required to be furnished regarding certain related party transactions of certain foreign corporations and certain foreign-owned domestic corporations. The regulations also increase the amount of certain penalties, and make certain other changes, to reflect the statutory changes made by the Taxpayer Relief Act of 1997.
T.D. 9266(HTML)	IRB #2006-28(HTML)	July 10, 2006
Final regulations under sections 3102 and 3121 of the Code contain amendments to the employment tax regulations. The regulations provide guidance concerning the application of the Federal Insurance Contributions Act (FICA) to cash payments made for service not in the course of the employer's trade or business, for domestic service in a private home of the employer, for agricultural labor, and for service performed as a home worker within the meaning of section 3121(d)(3)(C).
Announcement 2006-47(HTML)	IRB #2006-28(HTML)	July 10, 2006
This document contains corrections to proposed regulations (REG-134317-05, 2006-26 I.R.B. 1184) relating to guidance necessary to facilitate business electronic filing and burden reduction.
Rev. Rul. 2006-34(HTML)	IRB #2006-26(HTML)	June 26, 2006
Real property interests; closely held business. This ruling updates the guidance provided by Rev. Ruls. 75-365, 75-366, and 75-367, and provides certain safe harbors and a non-exclusive list of factors that are likely to be relevant in determining whether a deceased owner's activities with regard to certain real property were sufficiently active to support a finding that the real property interest constitutes a closely held business interest for purposes of section 6166 of the Code. Rev. Rul. 75-365 revoked and Rev. Rul. 75-367 revoked in part.
T.D. 9264(HTML)	IRB #2006-26(HTML)	June 26, 2006
Final, temporary, and proposed regulations under section 1502 of the Code and others simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
Rev. Proc 2006-28(HTML)	IRB #2006-25(HTML)	June 19, 2006
Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individuals from meeting those requirements. A list of the country for tax year 2005 and the date that country is subject to the section 911(d)(4) waiver is provided.
Rev. Proc 2006-21(HTML)	IRB #2006-24(HTML)	June 12, 2006
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 2006-26(HTML)	IRB #2006-18(HTML)	May 1, 2006
This document contains corrections to final regulations under section 163(d) of the Code (T.D. 9191, 2005-15 I.R.B. 854) regarding rules relating to how and when taxpayers may elect to take qualified dividend income into account as investment income for purposes of calculating the deduction for investment income expense.
Announcement 2006-22(HTML)	IRB #2006-16(HTML)	April 17, 2006
This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standard. Instead, it reports on the structure and activities of the APA program.
Notice 2006-36(HTML)	IRB #2006-15(HTML)	April 10, 2006
Public comments are requested on recommendations for items that should be included on the 2006-2007 Guidance Priority List. Taxpayers may submit recommendations for guidance at any time during the year. Recommendations submitted by May 15, 2006, will be reviewed for possible inclusion on the original 2006-2007 Guidance Priority List. Recommendations received after May 15, 2006, will be reviewed for inclusion in the next periodic update.
Notice 2006-23(HTML)	IRB #2006-11(HTML)	March 13, 2006
Because Patriot’s Day falls on Monday, April 17, 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 18, 2006). This includes the payment of the first installment of estimated tax for 2007.
Notice 2006-16(HTML)	IRB #2006-09(HTML)	February 27, 2006
This notice provides examples of transactions that are not the same or substantially similar to those in Notice 2002-35 (i.e., are not “listed transactions”), such that the filing of Form 8886, Reportable Transaction Disclosure Statement, is not required. Further, for taxpayers who would be required to file a Form 8886 for transactions that are the same or substantially similar as those described in Notice 2002-35 solely as a result of the taxpayers’ interest in a pass-through entity, this notice creates a disclosure requirement safe harbor. Notice 2002-35 clarified and modified.
T.D. 9247(HTML)	IRB #2006-09(HTML)	February 27, 2006
Final and temporary regulations under section 861 of the Code provide an alternative method of valuing assets for purposes of apportioning expenses under the tax book value method of regulations section 1.861-9T.
Notice 2006-13(HTML)	IRB #2006-08(HTML)	February 21, 2006
This notice announces that the IRS and Treasury intend to issue final regulations under section 1503(d) of the Code to provide that a reasonable cause standard similar to proposed regulations section 1.1503(d)-1(c)(1) will apply to cure all late filings under section 1503(d). Prior to issuance of those regulations, taxpayers may rely on the reasonable cause procedure set forth in proposed regulations section 1.1503(d)-1(c)(1), as modified by this notice, to cure late filings under the current regulations. Additionally, until the final regulations are issued, taxpayers may choose to apply for relief for untimely section 1503(d) filings under the provisions of regulations sections 301.9100-1 through 301.9100-3 or elect to use the reasonable cause standard set forth in the proposed regulations as modified by this notice.
Notice 2006-05(HTML)	IRB #2006-04(HTML)	January 23, 2006
This notice provides information to payees/filers who receive payments of interest on qualified education loans who are unable to comply with the reporting requirements for loan origination fees and capitalized interest under section 6050S of the Code and the regulations for calendar year 2005 returns. The notice explains that a payee/filer who is unable to comply with the reporting requirements for loan origination fees and capitalized interest may request that the Service waive, upon a showing of reasonable cause under section 6724 and the regulations, any penalty that might otherwise be imposed under sections 6721 or 6722 for failure to report these amounts.
Rev. Proc. 2006-13(HTML)	IRB #2006-03(HTML)	January 17, 2006
Reporting requirements; fair market value of conversion; Roth IRAs. This procedure provides safe harbor methods for determining the fair market value of an annuity contract that has not yet been annuitized for purposes of determining the amount includible in gross income as a result of a conversion of a traditional IRA to a Roth IRA, as described in Q&A–14 of section 1.408A–4T.
T.D. 9233(HTML)	IRB #2006-03(HTML)	January 17, 2006
Final regulations under section 3121 of the Code provide guidance for payments made on account of sickness or accident disability under a workers’ compensation law for purposes of the Federal Insurance Contributions Act (FICA).
Rev. Rul. 2006-02(HTML)	IRB #2006-01(HTML)	January 9, 2006
Section 351. The conclusion in Rev. Rul. 74-503 that a transferor's basis in transferee stock received in exchange for transferor stock is determined under section 362(a) of the Code is incorrect. The other conclusions in the ruling are under study. Rev. Rul. 74-503 revoked.
Rev. Proc. 2006-09(HTML)	IRB #2006-02(HTML)	January 9, 2006
This procedure explains the manner in which taxpayers may request an advance pricing agreement (APA) from the APA Program within the Office of the Associate Chief Counsel (International), the manner in which such a request will be processed by the APA Program, and the effect and administration of APAs. Rev. Proc. 2004-40 superseded.
Rev. Proc. 2006-08(HTML)	IRB #2006-01(HTML)	January 3, 2006
User fees for employee plans and exempt organizations. Up-to-date guidance for complying with the user fee program of the Service as it pertains to requests for letter rulings, determination letters, etc., on matters under the jurisdiction of the Office of the Division Commissioner, Tax Exempt and Government Entities, is provided. Rev. Proc. 2005-8 superseded.

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2006 IRB Documents That Provide Guidance to Tax Professionals

2006 IRB Documents That Provide Guidance
to Tax Professionals