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IRB 2006-24

Table of Contents
(Dated June 12, 2006)
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This is the table of contents of Internal Revenue Bulletin IRB 2006-24. 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

Temporary and proposed regulations concern the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities, to certain transactions involving computer software. A public hearing on the proposed regulations is scheduled for August 29, 2006.

Temporary and proposed regulations concern the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities, to certain transactions involving computer software. A public hearing on the proposed regulations is scheduled for August 29, 2006.

Proposed regulations under section 21 of the Code conform the rules relating to the child and dependent care credit to statutory changes including amendments under the Working Families Tax Relief Act of 2004, and address significant issues that have arisen administratively. The regulations are renumbered to conform to the renumbering of the statute.

This notice informs trustees and middlemen of non-mortgage widely held fixed investment trusts (NMWHFITs) that the date for satisfying the qualified NMWHFIT exception in regulations section 1.671-5(c)(2)(iv)(E) is extended by 60 days.

This notice announces that the IRS and Treasury intend to issue final regulations under sections 897(d) and (e) of the Code, which will revise the current rules under temporary regulations sections 1.897-5T and 1.897-6T and Notice 89-85, 1989-2 C.B. 403. When finalized, regulations will revise temporary regulations section 1.897-5T(c)(4) to take into account inbound statutory mergers and consolidations described in section 368(a)(1)(A). The regulations will also revise the rules of temporary regulations section 1.897-6T(b)(1) to take into account foreign-to-foreign statutory mergers and consolidations described in section 368(a)(1)(A) and to create two new exceptions to gain recognition under section 1.897-6(b)(1) for certain foreign-to-foreign asset reorganizations. The regulations will also revise the stock disposition rule of temporary regulations section 1.897-6T(b)(1)(iii) and eliminate the conditions specified for nonrecognition in temporary regulations section 1.897-6T(b)(2). Lastly, the regulations will modify the period that must be considered for imposing taxes and accrued interest on prior dispositions of the stock of foreign corporations. Notice 89-85 amplified.

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.

Insurance companies; interest rate tables. This announcement corrects an error in Rev. Rul. 2006-25, 2006-20 I.R.B. 882 (May 15, 2006).

This document contains corrections to final regulations (T.D. 9243, 2006-8 I.R.B. 475) that amend the income tax regulations under various provisions of the Code to account for statutory mergers and consolidations.



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