This announcement renews the Tax Exempt Bond (TEB) Mediation Pilot Program set forth in Announcement 2003-36, 2003-1 C.B. 1093, for an additional one-year period beginning on July 3, 2006.

Temporary and proposed regulations under section 7874(a)(2)(B) of the Code provide rules for determining whether a foreign corporation is a surrogate foreign corporation. Specifically, the regulations explain when there is an indirect acquisition of a domestic corporation’s properties for purposes of section 7874(a)(2)(B). The regulations provide guidance for determining when the expanded affiliated group has substantial business activities in a foreign country for purposes of section 7874(a)(2)(B)(iii). In addition, the regulations include a rule that in certain situations, a publicly traded partnership may be treated as a surrogate foreign corporation. The regulations also provide rules for the treatment of options of the surrogate foreign corporation for purposes of section 7874(a)(2)(B)(ii). A public hearing on the proposed regulations is scheduled for October 24, 2006.

Temporary and proposed regulations under section 7874(a)(2)(B) of the Code provide rules for determining whether a foreign corporation is a surrogate foreign corporation. Specifically, the regulations explain when there is an indirect acquisition of a domestic corporation’s properties for purposes of section 7874(a)(2)(B). The regulations provide guidance for determining when the expanded affiliated group has substantial business activities in a foreign country for purposes of section 7874(a)(2)(B)(iii). In addition, the regulations include a rule that in certain situations, a publicly traded partnership may be treated as a surrogate foreign corporation. The regulations also provide rules for the treatment of options of the surrogate foreign corporation for purposes of section 7874(a)(2)(B)(ii). A public hearing on the proposed regulations is scheduled for October 24, 2006.

Proposed regulations under sections 367 and 1248 of the Code set forth principles for the attribution of earnings and profits to shares of stock of current or former controlled foreign corporations that participate in certain nonrecognition transactions. The regulations also provide that, for purposes of section 1248, when a foreign partnership sells stock of a corporation, the partners of the partnership are treated as selling their proportionate shares of such stock.

This notice postpones until October 16, 2006, the due date for filing Form 8898, Statement for Individuals Who Begin or End Bona Fide Residence in a U.S. Possession, for tax years 2001 through 2005.

This procedure contains revisions to Publication 1239, Specifications for Filing Form 8027, Employer’s Annual Information Return of Tip Income and Allocated Tips, Electronically or Magnetically. Rev. Proc. 2005-41 superseded.

This procedure provides guidance on revoking an election under section 83(b) of the Code. The procedure sets forth the requirements that must be satisfied before permission to revoke the election can be granted. Additionally, it sets forth the information that must be provided when requesting permission to revoke an election under section 83(b).

This document provides notice of a public hearing on proposed regulations (REG-146459-05, 2006-8 I.R.B. 504) under sections 402(g), 402A, 403(b), and 408A of the Code relating to designated Roth accounts. A public hearing is scheduled for July 26, 2006.

This announcement renews the Tax Exempt Bond (TEB) Mediation Pilot Program set forth in Announcement 2003-36, 2003-1 C.B. 1093, for an additional one-year period beginning on July 3, 2006.

This document contains a correction to final regulations (T.D. 9254, 2006-13 I.R.B. 662) that apply when a member of a consolidated group transfers subsidiary stock at a loss. They also apply when a member holds loss shares of subsidiary stock and the subsidiary ceases to be a member of the group.