INCOME TAX
Rev. Rul. 2006-58(HTML)
Charitable remainder trust; real estate investment trust
(REIT). This ruling illustrates the application of section 860E of
the Code where a charitable remainder trust is a shareholder
of a real estate investment trust (REIT) or a partner of a partnership,
and the REIT or the partnership has excess inclusion income.
T.D. 9287(HTML)
Final regulations under section 7702 of the Code explain how
to determine the attained age of an insured for purposes of
testing whether a contract qualifies as a life insurance contract
for federal income tax purposes.
T.D. 9290(HTML)
Final regulations under section 6320 of the Code relate to a
taxpayer's right to a hearing after the filing of a notice of federal
tax lien (NFTL). The regulations make certain clarifying changes
in the way collection due process hearings are conducted and
specify the period during which a taxpayer may request an
equivalent hearing.
T.D. 9291(HTML)
Final regulations under section 6330 of the Code relate to a
taxpayer's right to a hearing before or after levy. The regulations
make certain clarifying changes in the way collection due
process hearings are conducted and specify the period during
which a taxpayer may request an equivalent hearing.
Notice 2006-96(HTML)
This notice provides transitional guidance on the new definitions
of "qualified appraisal" and "qualified appraiser" in section
170(f)(11) of the Code for purposes of substantiating deductions
for charitable contributions of property. The notice
also provides guidance on complying with new section 6695A,
regarding penalties for appraisals that result in substantial or
gross valuation misstatements under section 6662.
Notice 2006-97(HTML)
This notice provides interim guidance (and requests comments
and suggestions for further guidance) under sections 860E(d)
and 7701(i)(3) of the Code, relating to the taxation and reporting
of excess inclusion income of pass-through entities, including
real estate investment trusts (REITs) that own taxable mortgage
pools or residual interests in real estate mortgage investment
conduits (REMICs).
Notice 2006-99(HTML)
This notice provides guidance on withholding and information
reporting on foreign persons and includes guidance on certain
book-entry systems in foreign countries. It also announces that
the IRS and Treasury intend to issue regulations providing that
regulations section 1.871-14(e), dealing with foreign targeted
registered obligations, will not apply to obligations issued after
December 31, 2006, except in limited circumstances. Finally,
this notice announces that the IRS and Treasury intend to issue
regulations retroactively removing the rule in regulations section
1.1441-1(b)(7)(iii) that purports to impose interest under
section 6601 when no underlying tax liability has in fact been
imposed.
Announcement 2006-88(HTML)
This announcement is a ministerial update to Notice 2006-27,
2006-11 I.R.B. 626, and Notice 2006-28, 2006-11 I.R.B.
628, and announces that taxpayers may use either RESNET
Publication No. 05-001 or RESNET Publication No. 06-001 to
determine whether a dwelling unit qualifies for the new energy
efficient home credit. This announcement also provides for developers
of software to submit applications to be included on a
public list of software programs that may be used in calculating
energy consumption for purposes of obtaining a section 45L
certification by using standards prescribed in either RESNET
publication. This change is effective for new energy efficient
homes acquired after December 31, 2005. Notices 2006-27
and 2006-28 modified.
EMPLOYEE PLANS
Notice 2006-98(HTML)
2007 cost-of-living adjustments; retirement plans, etc.
This notice sets forth certain cost-of-living adjustments effective
January 1, 2007, applicable to the dollar limits on benefits
under qualified defined benefit pension plans and to other provisions
affecting (1) certain plans of deferred compensation and
(2) "control employees." This notice restates the data in News
Release IR-2006-162 issued October 18, 2006.
EXEMPT ORGANIZATIONS
Rev. Rul. 2006-58(HTML)
Charitable remainder trust; real estate investment trust
(REIT). This ruling illustrates the application of section 860E of
the Code where a charitable remainder trust is a shareholder
of a real estate investment trust (REIT) or a partner of a partnership,
and the REIT or the partnership has excess inclusion income.
Notice 2006-97(HTML)
This notice provides interim guidance (and requests comments
and suggestions for further guidance) under sections 860E(d)
and 7701(i)(3) of the Code, relating to the taxation and reporting
of excess inclusion income of pass-through entities, including
real estate investment trusts (REITs) that own taxable mortgage
pools or residual interests in real estate mortgage investment
conduits (REMICs).
EMPLOYMENT TAX
Rev. Rul. 2006-56(HTML)
Excess per diem allowances. This ruling provides that
where an expense allowance arrangement has no mechanism
or process to track allowances paid and routinely pays per
diem allowances in excess of the federal per diem rates
without requiring actual substantiation of all the expenses or
repayment of the excess amount, all payments made under the
arrangement will be treated as made under a nonaccountable plan.
Notice 2006-102(HTML)
2007 social security contribution and benefit base; domestic
employee coverage threshold. The Commissioner
of the Social Security Administration has announced (1) the
OASDI contribution and benefit base for remuneration paid in
2007 and self-employment income earned in taxable years
beginning in 2007, and (2) the domestic employee coverage
threshold amount for 2007.
ADMINISTRATIVE
T.D. 9290(HTML)
Final regulations under section 6320 of the Code relate to a
taxpayer's right to a hearing after the filing of a notice of federal
tax lien (NFTL). The regulations make certain clarifying changes
in the way collection due process hearings are conducted and
specify the period during which a taxpayer may request an
equivalent hearing.
T.D. 9291(HTML)
Final regulations under section 6330 of the Code relate to a
taxpayer's right to a hearing before or after levy. The regulations
make certain clarifying changes in the way collection due
process hearings are conducted and specify the period during
which a taxpayer may request an equivalent hearing.
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