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IRB 2006-51

Table of Contents
(Dated December 18, 2006)
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This is the table of contents of Internal Revenue Bulletin IRB 2006-51. 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

This notice provides guidance to employers and payers on their reporting and wage withholding requirements for calendar years 2005 and 2006 with respect to deferrals of compensation and amounts includible in gross income under section 409A of the Code. Notice 2005-1 modified. Notice 2005-94 superseded.

Charitable contributions by payroll deductions. This notice explains how taxpayers that make charitable contributions by payroll deductions may meet the recordkeeping requirements of section 170(f)(17) of the Code, as added by the Pension Protection Act of 2006. The notice also provides that taxpayers may rely on this notice to comply with the new requirements until subsequent regulations are effective.

EMPLOYEE PLANS

Diversification; transition rules; defined contribution plans. This notice provides transitional rules with respect to the diversification requirements of publicly traded securities for certain defined contribution plans, requests comments on the transitional guidance (as well as comments for regulations), and contains a model notice that employers may give their affected employees.

EXEMPT ORGANIZATIONS

This notice provides interim guidance to certain section 501(c)(3) organizations and related taxpayers regarding new legislation in the Pension Protection Act of 2006 (Act) applicable to private foundations, supporting organizations, and charitable organizations that maintain donor advised funds. The notice also solicits comments regarding this guidance and other provisions under the Act that might impact similarly situated taxpayers.

A list is provided of organizations now classified as private foundations.

SELF-EMPLOYMENT TAX

This notice contains a proposed revenue ruling and requests comments concerning the proposed holding that Conservation Reserve Program (CRP) rental payments (including incentive payments) from the United States Department of Agriculture to (1) a farmer actively engaged in the trade or business of farming who enrolls land in CRP and fulfills the CRP contractual obligations personally and to (2) an individual not otherwise actively engaged in the trade or business of farming who enrolls land in CRP and fulfills the CRP contractual obligations by arranging for a third party to perform the required activities are both includible in net income from self-employment for purposes of the Self-Employment Contributions Act (SECA) tax and not excluded from net income from self-employment as rentals from real estate.

ADMINISTRATIVE

This document contains a correction to proposed regulations (REG-103039-05, 2006-49 I.R.B. 1057) by cross-reference to temporary regulations relating to the disclosure of reportable transactions by material advisors.

This announcement alerts the public regarding updated procedures for closing cases involving listed transactions when settlement on listed transactions was not able to be reached in the Office of Appeals.



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