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IRB 2006-45

Table of Contents
(Dated November 6, 2006)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2006-45. 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

2006 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2006, is published as required by section 995(f) of the Code.

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for November 2006.

Final regulations under section 752 of the Code contain rules for taking into account certain obligations of a business entity that is disregarded as separate from its owner under section 856(i) or section 1361(b)(3), or regulations sections 301.7701-1 through 301.7701-3. The regulations clarify the existing regulations concerning when a partner may be treated as bearing the economic risk of loss for a partnership liability based upon an obligation of a disregarded entity.

This notice provides rules interpreting the reasonable mortality charge requirement contained in section 7702(c)(3)(B)(i) of the Code. Notice 88-128 supplemented. Notice 2004-61 modified and superseded.

TAX CONVENTIONS

The United States recently exchanged instruments of ratification for a new income tax treaty with Bangladesh and a new protocol with Sweden. The tables in this announcement can be used to supplement the tables in Publications 515 and 901.

The document describes how certain taxpayers may elect to use dual consolidated losses subject to section 1503(d) of the Code either in the United States or the United Kingdom, and contains background information for that election.

ADMINISTRATIVE

This document provides procedures under which a taxpayer may use the automatic consent procedures of Rev. Proc. 2002-9 to request a change in method of accounting to comply with regulations sections 1.168(k)-1 or 1.1400L(b)-1. Rev. Proc. 2002-9 modified and amplified.

This document provides the exclusive procedures for a corporation to obtain automatic approval from the Commissioner to change an annual accounting period under section 442 of the Code. Rev. Proc. 2002-37 clarified, modified, amplified, and superseded.

This document provides the exclusive procedures for a partnership, S corporation, electing S corporation, personal service corporation, or trust to obtain automatic approval from the Commissioner to adopt, change, or retain an annual accounting period under section 442 of the Code. Rev. Proc. 2002-38 clarified, modified, amplified, and superseded.

This document provides methods to determine the amount of “paragraph (e)(1) wages” for purposes of the limitation contained in section 199(b)(1) on the amount of the deduction provided by section 199(a)(1) for income attributable to domestic production activities. The procedure reflects changes in the definition of “W-2 wages” for purposes of section 199 made by the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA).

This document contains corrections to final and temporary regulations (T.D. 9281, 2006-39 I.R.B. 517) relating to the determination of the interest expense deduction of foreign corporations and applies to foreign corporations engaged in a trade or business within the United States.

This document contains corrections to final regulations (T.D. 9276, 2006-37 I.R.B. 423) concerning the definition of supplemental wages for income tax withholding purposes and income tax requirements for employers making payments of supplemental wages to employees.



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