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IRB 2006-37

Table of Contents
(Dated September 11, 2006)
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This is the table of contents of Internal Revenue Bulletin IRB 2006-37. 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

Mutual life insurance companies; recomputed differential earnings rate. The recomputed differential earnings rate for 2004 is determined for use by mutual life insurance companies to compute their income tax liability for 2005.

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.

The 2006 Form 8830, Enhanced Oil Recovery Credit, will not be issued for the 2007 processing year since the credit is completely phased out for 2006 due to the increased applicable reference price of crude oil.

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.

EXEMPT ORGANIZATIONS

The IRS has revoked its determination that Youth Ministries, Inc., d/b/a Operation Rescue West, of Wichita, KS, no longer qualifies as an organization described in sections 501(c)(3) and 170(c)(2) of the Code.

EMPLOYMENT TAX

Final regulations under section 3402 of the Code concern the definition of supplemental wages for income tax withholding purposes and income tax withholding requirements for employers making payments of supplemental wages to employees.

ADMINISTRATIVE

This revenue procedure announces new user fees that will be charged by the Service to process Form 8802, Application for United States Residency Certification. The user fee will be charged for all Form 8802 applications submitted with a postmark date on or after October 2, 2006. The rules for these user fees are set forth and will be incorporated in the next revision of Form 8802 and accompanying instructions.

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.

This document contains corrections to proposed regulations (REG-135866-02, 2006-27 I.R.B. 34) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions.

This document contains additional corrections to proposed regulations (REG-135866-02, 2006-27 I.R.B. 34) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions.

This document contains corrections 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.



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