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IRB 2006-11

Table of Contents
(Dated March 13, 2006)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2006-11. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Final regulations under sections 367(a) and (b) of the Code concern transfers pursuant to section 304(a)(1). Rev. Ruls. 91-5 and 92-86 modified.

Final regulations under section 951(a) of the Code provide special rules to ensure that earnings and profits of a controlled foreign corporation attributable to a section 304 transaction will not be allocated in a manner that results in the avoidance of income tax and to ensure that earnings and profits of a controlled foreign corporation are not allocated to certain preferred stock in a manner inconsistent with the economic interest that such stock represents.

Low-income housing tax credit; private activity bonds. Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas are provided for purposes of determining the 2006 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k)(5).

This notice establishes the qualifying advanced coal project program under section 48A of the Code.

This notice establishes the qualifying gasification project program under section 48B of the Code.

This notice provides procedures that manufacturers may follow to certify property as either an Eligible Building Envelope Component or Qualified Energy Property, as well as guidance regarding the conditions under which taxpayers seeking to claim the section 25C nonbusiness energy property credit may rely on a manufacturer’s certification.

This notice provides a procedure that an eligible contractor may follow to certify that a dwelling unit, other than a manufactured home, is an energy efficient home that satisfies the requirements of sections 45L(c)(1)(A) and (B) of the Code.

This notice provides a procedure that an eligible contractor may follow to certify that a manufactured home is an energy efficient home that satisfies the requirements of section 45L(c)(2) or (3) of the Code.

ADMINISTRATIVE

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.

This document contains corrections to final and temporary regulations (T.D. 9192, 2005-15 I.R.B. 866) relating to guidance concerning the determination of the tax attributes that are available for reduction and the method for reducing those attributes when a member of a consolidated group excludes discharge of indebtedness income from gross income under section 108 of the Code.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.