2005 Miscellaneous IRS Documents

These "Miscellaneous IRS Documents" published in The Internal Revenue Bulletin (IRB), the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service, and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.

Included here are such documents as: Tax Conventions, Public Laws, Court Decisions, Railroad Retirement Board Quarterly Reports, information pertaining to Social Security taxes, and Scenarios of Disciplinary Actions as issued by the Office of the Director of Practice. Please note that NOT all of these types of documents are published in the IRB.

Miscellaneous IRS Documents are either in HTML or in the Adobe Acrobat PDF format. Internal Revenue Bulletin Summary pages are in HTML format.


Court Decisions	Bulletin	Date of IRB

Ct. D. 2080(PDF, 99K)	IRB #2005-15(HTML)	April 11, 2005
Gross income; litigant’s recovery includes attorney’s contingent fee. The Supreme Court holds that when a litigant’s recovery constitutes income, the litigant’s income includes the portion of the recovery paid to the attorney as a contingent fee. Commissioner of Internal Revenue v. Banks.

Tax Conventions	Bulletin	Date of IRB

Announcement 2005-77(HTML)	IRB #2005-44(HTML)	October 31, 2005
U.S.-Republic of Cape Verde reciprocal exemption agreement. The United States and the Republic of Cape Verde have entered into a diplomatic note evidencing an agreement for the reciprocal exemption of income from the international operation of a ship or ships or aircraft for taxable years beginning on or after January 1, 2005.
Announcement 2005-72(HTML)	IRB #2005-41(HTML)	October 11, 2005
U.S.-Mexico MAP Agreement regarding eligibility of fiscally transparent entities to benefits. A copy of the news release issued by the Director, International (U.S. Competent Authority), on September 19, 2005 (IR-2005-17), is set forth.
Notice 2005-53(HTML)	IRB #2005-32(HTML)	August 8, 2005
This notice provides supplemental guidance for foreign banks concerning interest expense allocation. The notice also indicates that the Treasury Department and the IRS are evaluating foreign banking industry data to determine whether the 93-percent fixed ratio in step 2 of the interest expense allocation formula under regulations section 1.882-5 should be increased, and whether the fair market value election for valuing U.S. assets should require the use of the actual ratio in step 2. The notice also permits taxpayers who use the adjusted U.S. book liability method to calculate excess interest by reference to a published LIBOR rate rather than the taxpayer’s actual non-U.S.-based dollar borrowing rate.
Announcement 2005-47(HTML)	IRB #2005-28(HTML)	July 11, 2005
This announcement provides a memorandum of understanding (MOU) between the Competent Authorities of the United States and Canada regarding the mutual agreement procedure (MAP) process in accordance with the terms set forth in the United States - Canada income tax convention. The MOU establishes principles and guidelines to improve the performance and efficiency of the MAP process.
Announcement 2005-22(PDF, 38K)	IRB #2005-14(HTML)	April 4, 2005
This agreement describes taxation of certain scholarships under the U.S.-Austria Income Tax Treaty. A copy of the News Release issued by the Director, International (U.S. Competent Authority), on March 1, 2005 (IR-2005-20), is set forth.
Announcement 2005-3(PDF, 69K)	IRB #2005-2(HTML)	Jan. 10, 2005
U.S. and Swiss pension plans for tax treaty benefits. A copy of the news release issued by the Director, International (U.S. Competent Authority), on December 10, 2004, is set forth.

Special Announcements	Bulletin	Date of IRB

Announcement 2005-88(PDF, 99K)	IRB #2005-50(HTML)	December 12, 2005
This announcement solicits applications from potential partners to participate in the 2006 IRS Individual e-file Partnership Program. The partnership opportunities support RRA 98 which requires the IRS to receive 80% of all returns electronically by 2007. RRA 98 authorized the IRS Commissioner to promote the benefits and encourage the use of e-file services through partnerships with various entities that offer low cost tax preparation and electronic filing of income tax returns for qualified taxpayers. Applicants that are accepted as partners will have a link(s) and description(s) of their services placed on irs.gov (IRS e-file Partners Page).
Announcement 2005-81(PDF, 99K)	IRB #2005-45(HTML)	November 7, 2005
The Eighteenth Annual Institute on Current Issues in International Taxation, jointly sponsored by the Internal Revenue Service and The George Washington University Law School, will be held on December 8 and 9, 2005, at the J.W. Marriott Hotel in Washington, DC.
Announcement 2005-80(PDF, 99K)	IRB #2005-45(HTML)	November 7, 2005
This announcement provides a settlement initiative under which taxpayers and the Internal Revenue Service may resolve the tax treatment of certain tax transactions. Taxpayers have until January 23, 2006, to file an election indicating their intent to participate in this initiative.
Announcement 2005-69(PDF, 99K)	IRB #2005-40(HTML)	October 3, 2005
This announcement informs issuers of tax-exempt bonds that the Service will immediately put into effect procedures to provide relief to issuers affected by Hurricane Katrina. Affected issuers are provided additional time to file forms required under section 149(e) of the Code and to make payments required under section 149(f). In addition, affected issuers may also be granted other relief under appropriate circumstances.

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