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IRB 2006-43

Table of Contents
(Dated October 23, 2006)
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This is the table of contents of Internal Revenue Bulletin IRB 2006-43. 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 under section 45G of the Code provide guidance regarding the railroad track maintenance credit determined for qualified railroad track maintenance expenditures paid or incurred by a Class II or Class III railroad and other eligible taxpayers during the taxable year. A public hearing on the proposed regulations is scheduled for January 9, 2007.

Temporary and proposed regulations under section 45G of the Code provide guidance regarding the railroad track maintenance credit determined for qualified railroad track maintenance expenditures paid or incurred by a Class II or Class III railroad and other eligible taxpayers during the taxable year. A public hearing on the proposed regulations is scheduled for January 9, 2007.

Proposed regulations under section 853 of the Code would eliminate country-by-country reporting by a regulated investment company (RIC) to its shareholders of foreign source income received by the RIC and foreign taxes paid by the RIC. Under these regulations, the IRS and the Treasury Department would continue to require the reporting of per-country information by RICs to the IRS because this information remains relevant to monitoring compliance with the foreign tax credit provisions.

This notice sets forth additional transition relief under section 409A. The notice generally extends through December 31, 2007, the transition relief that previously had been provided through December 31, 2006, subject to certain exceptions.

This notice provides adjustments to the limitation on housing expenses for purposes of section 911 of the Code for specific locations, based on geographic differences in housing costs, relative to housing costs in the United States.

EMPLOYEE PLANS

This notice sets forth additional transition relief under section 409A. The notice generally extends through December 31, 2007, the transition relief that previously had been provided through December 31, 2006, subject to certain exceptions.

Section 906 of Pension Protection Act of 2006; transition rule. This notice provides transition relief for plans of Indian tribal governments to comply with the changes made by section 906 of the Pension Protection Act of 2006 under a reasonable and good faith standard, pending further guidance. The notice also provides for Indian tribal governments to implement a new plan for commercial employees by September 30, 2007, to satisfy this standard as a part of this transition relief.

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for October 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth.

EXCISE TAX

Resellers of air transportation. This ruling explains the tax consequences under section 4261 of the Code when a traveler purchases a ticket for taxable transportation from a third party intermediary other than the airline. Rev. Ruls. 75-296 and 80-31 distinguished.

This notice provides guidance on the alternative fuel and alternative fuel mixture credit and payments and the imposition of tax on alternative fuel and alternative fuel mixtures. The notice also provides guidance on the excise tax exemption for blood collector organizations.

ADMINISTRATIVE

Per diem allowances. This procedure provides optional rules for deeming substantiated the amount of certain business expenses of traveling away from home reimbursed to an employee or deductible by an employee or self-employed individual. Rev. Proc. 2005-67 superseded.

This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing (REG-112994-06, 2006-27 I.R.B. 47) relating to the determination of whether a foreign entity shall be treated as a surrogate foreign corporation under section 7874(a)(2)(B) of the Code.



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