2006 Miscellaneous IRS Documents Issued in IRS's Weekly Internal Revenue Bulletin

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 in HTML format. Internal Revenue Bulletin Summary pages are in HTML format.


Court Decisions	Bulletin	Date of IRB

Court Decision 2081(HTML)	IRB #2006-13(HTML)	March 27, 2006
IRA assets; bankruptcy estate. The Supreme Court holds that a taxpayer can exempt IRA assets from the bankruptcy estate because the IRAs fulfill both of the Bankruptcy Code section 522(d)(10)(E) requirements at issue here-they confer a right to receive payment on account of age, and they are similar plans or contracts to those enumerated in section 522(d)(10)(E). Rousey, et ux., v. Jacoway.

Court Decision 2082(HTML)	IRB #2006-14(HTML)	April 3, 2006
Sale of seized real property by IRS; federal tax delinquency. The Supreme Court holds that the national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal-question jurisdiction over the disputed issue on removal. Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing.

Tax Conventions	Bulletin	Date of IRB

Announcement 2006-86(HTML)	IRB #2006-45(HTML)	Nov. 6, 2006
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.
Announcement 2006-80(HTML)	IRB #2006-45(HTML)	Nov. 6, 2006
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.
Announcement 2006-08(HTML)	IRB #2006-04(HTML)	January 23, 2006
This document announces the mutual agreement between the U.S. and Mexican Competent Authorities that specifies the case in which fiscally transparent entities are entitled to treaty benefits and clarifies the procedures for claiming those benefits under the U.S.-Mexico income tax treaty.
Announcement 2006-07(HTML)	IRB #2006-04(HTML)	January 23, 2006
This document announces the memorandum of understanding (MOU) signed by the U.S. and Canadian Competent Authorities concerning the principles, guidelines, and procedures to resolve disagreements about underlying facts and circumstances in cases that are referred to them under the mutual agreement procedure (MAP) article of the U.S.-Canada income tax treaty.
Announcement 2006-06(HTML)	IRB #2006-04 (HTML)	January 23, 2006
This document announces the memorandum of understanding (MOU) signed by the U.S. and Japanese Competent Authorities concerning the meaning of the term “investment bank” under Article 11(3)(c)(i) of the U.S.-Japan income tax treaty.

Social Security Documents	Bulletin	Date of IRB

Notice 2006-102(HTML)	IRB #2006-46(HTML)	Nov. 13, 2006
2007 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OASDI contribution and benefit base for remuneration paid in 2007 and self-employment income earned in taxable years beginning in 2007, and (2) the domestic employee coverage threshold amount for 2007.

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