2006 Notices
A "Notice" is a public pronouncement that may contain guidance that involves substantive interpretations of the Code or other provisions of law. . For example, "notices" can be used to relate what regulations will say in situations where the regulations may not be published in the immediate future.
Under Revenue Ruling 90-91, "for purposes of applying the substantial understatement portion of the accuracy-related penalty, ...all notices and announcements issued by the Service and published in the Internal Revenue Bulletin are considered authority and may be relied upon to the same extent as a revenue ruling or revenue procedure."
| Notices |
Bulletin |
Date of IRB |
 |
| Notice 2006-111(HTML) |
IRB #2006-52(HTML) |
Dec. 26, 2006 |
| Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for Dec. 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-110(HTML) |
IRB #2006-51(HTML) |
Dec. 18, 2006 |
| 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. |
| Notice 2006-109(HTML) |
IRB #2006-51(HTML) |
Dec. 18, 2006 |
| 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. |
| Notice 2006-108(HTML) |
IRB #2006-51(HTML) |
Dec. 18, 2006 |
| 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. |
| Notice 2006-107(HTML) |
IRB #2006-51(HTML) |
Dec. 18, 2006 |
| 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. |
| Notice 2006-106(HTML) |
IRB #2006-49(HTML) |
Dec. 4, 2006 |
| This notice provides tables that show the amount of an individual's wages, salary, or other income that is exempt from a notice of levy used to collect delinquent tax in 2007. |
| Notice 2006-105(HTML) |
IRB #2006-50(HTML) |
Dec. 11, 2006 |
| Minimum funding standards; alternative deficit reduction contribution. This notice describes how a commercial passenger airline may make an election of an alternative deficit reduction contribution pursuant to section 402(i) of the Pension Protection Act of 2006 and contains background for that election. Announcement 2004-38 modified. Announcement 2004-43 amplified and modified. Notice 2004-59 amplified. |
| Notice 2006-104(HTML) |
IRB #2006-48(HTML) |
Nov. 27, 2006 |
| Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for Nov. 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-103(HTML) |
IRB #2006-47(HTML) |
Nov. 20, 2006 |
| Because Patriots' Day falls on Monday, April 16, this notice provides individual taxpayers residing in Maine, Maryland, Massachusetts, New Hampshire, New York, Vermont, and the District of Columbia an additional day to file their federal income tax returns and make their payments (until April 17, 2007). The additional day applies to the payment of the first installment of estimated tax for 2007. |
| 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. |
| Notice 2006-101(HTML) |
IRB #2006-47(HTML) |
Nov. 20, 2006 |
| This notice updates Notice 2003-69, 2003-2 C.B. 851, which contains a list of the United States tax treaties that meet the requirements of section 1(h)(11)(C)(i)(II) of the Code. Notice 2003-69 amplified and superseded. |
| Notice 2006-100(HTML) |
IRB #2006-51(HTML) |
Dec. 18, 2006 |
| 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. |
| Notice 2006-99(HTML) |
IRB #2006-46(HTML) |
Nov. 13, 2006 |
| This notice provides guidance on withholding and information reporting on foreign persons and includes guidance on certain book-entry systems in foreign countries. It also announces that the IRS and Treasury intend to issue regulations providing that regulations section 1.871-14(e), dealing with foreign targeted registered obligations, will not apply to obligations issued after Dec. 31, 2006, except in limited circumstances. Finally, this notice announces that the IRS and Treasury intend to issue regulations retroactively removing the rule in regulations section 1.1441-1(b)(7)(iii) that purports to impose interest under section 6601 when no underlying tax liability has in fact been imposed. |
| Notice 2006-98(HTML) |
IRB #2006-46(HTML) |
Nov. 13, 2006 |
| 2007 cost-of-living adjustments; retirement plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2007, applicable to the dollar limits on benefits under qualified defined benefit pension plans and to other provisions affecting (1) certain plans of deferred compensation and (2) "control employees." This notice restates the data in News Release IR-2006-162 issued October 18, 2006. |
| Notice 2006-97(HTML) |
IRB #2006-46(HTML) |
Nov. 13, 2006 |
| This notice provides interim guidance (and requests comments and suggestions for further guidance) under sections 860E(d) and 7701(i)(3) of the Code, relating to the taxation and reporting of excess inclusion income of pass-through entities, including real estate investment trusts (REITs) that own taxable mortgage pools or residual interests in real estate mortgage investment conduits (REMICs). |
| Notice 2006-96(HTML) |
IRB #2006-46(HTML) |
Nov. 13, 2006 |
| This notice provides transitional guidance on the new definitions of "qualified appraisal" and "qualified appraiser" in section 170(f)(11) of the Code for purposes of substantiating deductions for charitable contributions of property. The notice also provides guidance on complying with new section 6695A, regarding penalties for appraisals that result in substantial or gross valuation misstatements under section 6662. |
| Notice 2006-95(HTML) |
IRB #2006-45(HTML) |
Nov. 6, 2006 |
| 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. |
| Notice 2006-94(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| 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. |
| Notice 2006-93(HTML) |
IRB #2006-44(HTML) |
October 30, 2006 |
| This notice provides guidance on the new information reporting requirements in section 6049 of the Code for payments of interest on state or local bonds that are excludable from gross income under section 103 (tax-exempt interest). |
| Notice 2006-92(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| 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. |
| Notice 2006-91(HTML) |
IRB #2006-42(HTML) |
October 16, 2006 |
| Extension of replacement period for livestock sold on account of drought. This notice explains the circumstances under which the 4-year replacement period under section 1033(e)(2) of the Code is extended for livestock sold on account of drought. The Appendix to this notice contains a list of counties that experienced exceptional, extreme, or severe drought conditions during the preceding 12 months. Taxpayers may use this list to determine if an extension is available. |
| Notice 2006-90(HTML) |
IRB #2006-42(HTML) |
October 16, 2006 |
| This notice announces a delay in the effective date of new user fee charges for processing Form 8802, Application for United States Residency Certification. The new user fee will be charged for all Forms 8802 received with a postmark date on or after Nov. 1, 2006. Rev. Proc. 2006-35 modified. |
| Notice 2006-89(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| 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. |
| Notice 2006-88(HTML) |
IRB #2006-42(HTML) |
October 16, 2006 |
| Electricity produced from certain renewable resources; open-loop biomass. This notice sets forth interim guidance, pending the issuance of regulations, regarding the credit for electricity produced from open-loop biomass. |
| Notice 2006-87(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| 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. |
| Notice 2006-86(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| This notice provides interim guidance under section 152(c)(4) of the Code, the rule for determining which taxpayer may claim a qualifying child when two or more taxpayers claim the same child. It clarifies that, unless the special rule in section 152(e) applies, the tie-breaking rule in section 152(c)(4) applies to the head of household filing status, the child and dependent care credit, the child tax credit, the earned income credit, the exclusion for dependent care assistance, and the dependency deduction as a group, rather than on a section-by-section basis. |
| Notice 2006-85(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| This notice announces that the IRS and Treasury intend to issue regulations under section 367(b) to address certain triangular reorganizations involving foreign corporations. The regulations will apply to triangular reorganizations where either the parent corporation or its subsidiary are foreign and where the subsidiary acquires from the parent, in exchange for property, parent stock that is used to acquire the stock or assets of a target corporation. The regulations will treat the transfer of property from the subsidiary to its parent as a distribution of property under section 301(c) and make corresponding adjustments. |
| Notice 2006-84(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| This notice concludes that income from performing services at the U.S. Naval Base at Guantanamo Bay is not income earned in a restricted country (Cuba) for purposes of the limitation set forth in section 911(d)(8)(A) of the Code and thus, an individual working at Guantanamo Bay is eligible for the section 911 foreign earned income exclusion, provided that the other requirements of that section are met. |
| Notice 2006-83(HTML) |
IRB #2006-40(HTML) |
October 2, 2006 |
| This notice provides guidance to individual chapter 11 debtors and their bankruptcy estates regarding the tax treatment of post-petition income as the result of the enactment of section 1115 of the Bankruptcy Code by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. The notice also alerts information return preparers regarding their reporting responsibilities. |
| Notice 2006-82(HTML) |
IRB #2006-39(HTML) |
Sept. 25, 2006 |
| Extension of replacement period for livestock sold on account of drought. This notice explains the circumstances under which the 4-year replacement period under section 1033(e)(2) of the Code is extended for livestock sold on account of drought. The notice informs taxpayers that the Service will publish an annual list of counties that experienced exceptional, extreme, or severe drought conditions, which a taxpayer can use to determine if an extension is available. |
| Notice 2006-81(HTML) |
IRB #2006-40(HTML) |
October 2, 2006 |
| Section 355. This notice provides guidance for making an election under section 355(b)(3)(C) of the Code. |
| Notice 2006-80(HTML) |
IRB #2006-40(HTML) |
October 2, 2006 |
| Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for September 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-79(HTML) |
IRB #2006-43(HTML) |
October 23, 2006 |
| 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. |
| Notice 2006-78(HTML) |
IRB #2006-41(HTML) |
October 10, 2006 |
| This notice announces the phase-out of the qualified hybrid motor vehicle credit and the new advanced lean burn technology motor vehicle credit for passenger automobiles and light trucks manufactured by Toyota Motor Corporation that are purchased for use or lease in the United States beginning on October 1, 2006. |
| Notice 2006-77(HTML) |
IRB #2006-40(HTML) |
October 2, 2006 |
| This notice republishes Notice 2006-67, 2006-33 I.R.B. 248, to reflect the citations to the final regulations for the additional first year depreciation deduction provided by section 168(k) of the Code. The notice provides guidance with respect to the 50-percent additional first year depreciation deduction provided by section 1400N(d) of the Code for qualified Gulf Opportunity (GO) Zone property. Notice 2006-67 modified and superseded. Rev. Proc. 2002-9 modified and amplified. |
| Notice 2006-76(HTML) |
IRB #2006-38(HTML) |
Sept. 18, 2006 |
| This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether income is effectively connected with the conduct of a trade or business within such a U.S. possession or territory. |
| Notice 2006-75(HTML) |
IRB #2006-36(HTML) |
Sept. 5, 2006 |
| Weighted average interest rate modifications; corporate bond weighted average. This notice extends the use of the corporate bond weighted average interest rate for sections 412(c)(7)(E) and 412(l) of the Code and sections 302(c)(7)(E) and 302(d) of the Employee Retirement Income Security Act of 1974 as provided in section 301 of the Pension Protection Act of 2006. |
| Notice 2006-74(HTML) |
IRB #2006-35(HTML) |
August 28, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for August 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-73(HTML) |
IRB #2006-35(HTML) |
August 28, 2006 |
| This notice effects interim revisions to Forms 8898, Statement for Individuals Who Begin or End Bona Fide Residence in a U.S. Possession, and 8840, Closer Connection Exception Statement for Aliens. Taxpayers required to file these forms should disregard certain line items. However, filers are reminded that they must retain the information elicited on those line items, as well as the rest of the form, in their books and records. |
| Notice 2006-72(HTML) |
IRB #2006-36(HTML) |
Sept. 5, 2006 |
| This notice contains questions and answers that provide guidance on the information reporting requirements for qualified tuition and related expenses under section 6050S of the Code. |
| Notice 2006-71(HTML) |
IRB #2006-34(HTML) |
August 21, 2006 |
| This notice modifies Notice 2006-53, 2006-26 I.R.B. 1180, by extending the effective date of that publication from June 26, 2006, to Dec. 1, 2006. |
| Notice 2006-70(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| This notice states that the Treasury Department and IRS intend to amend the effective date provision of regulations section 1.7874-2T (and when it is finalized, 1.7874-2) so that it will not apply to certain acquisitions, otherwise described in section 7874(a)(2)(b)(i) of the Code which were completed on or after June 6, 2006, provided such acquisitions were entered into pursuant to a binding commitment which was in effect on Dec. 28, 2005. |
| Notice 2006-69(HTML) |
IRB #2006-31(HTML) |
July 31, 2006 |
| This notice provides further guidance on the use of debit cards to reimburse participants in health flexible spending arrangements (FSAs) and health reimbursement arrangements, including substantiating claimed medical expenses at the point-ofsale through an inventory information approval system. It also provides guidance on use of debit cards for dependent care FSAs. Rev. Rul. 2003-43 amplified. |
| Notice 2006-68(HTML) |
IRB #2006-31(HTML) |
July 31, 2006 |
| This notice alerts taxpayers who submit offers in compromise on or after July 16, 2006, that they must include a nonrefundable down payment with their offers. The notice also waives the down payment requirement for low-income taxpayers and taxpayers who submit offers based solely on doubt as to liability. July 31, 2006 2006-31 I.R.B. |
| Notice 2006-67(HTML) |
IRB #2006-33(HTML) |
August 14, 2006 |
| This notice provides guidance with respect to the 50-percent additional first year depreciation deduction provided by section 1400N(d) of the Code for qualified Gulf Opportunity (GO) Zone property. Rev. Proc. 2002-9 modified and amplified. |
| Notice 2006-66(HTML) |
IRB #2006-30(HTML) |
July 24, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for July 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-65(HTML) |
IRB #2006-31(HTML) |
July 31, 2006 |
| This document notifies the public of the new excise taxes and related disclosure requirements that target certain potentially abusive tax shelter transactions to which tax-exempt entities are parties. It also solicits comments regarding the new excise taxes and disclosure requirements. |
| Notice 2006-64(HTML) |
IRB #2006-29(HTML) |
July 17, 2006 |
| This notice provides interim guidance on the application of section 409A to accelerated payments to satisfy federal conflict of interest requirements. |
| Notice 2006-63(HTML) |
IRB #2006-29(HTML) |
July 17, 2006 |
| This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the notice seeks comments regarding any burdens associated with the record retention requirements that apply to issuers and other parties to tax-exempt bond transactions in order to substantiate compliance with section 103 of the Code. Comments should be received by October 16, 2006. |
| Notice 2006-62(HTML) |
IRB #2006-29(HTML) |
July 17, 2006 |
| 2006 enhanced oil recovery credit. The enhanced oil recovery credit for taxable years beginning in the 2006 calendar year is determined without regard to the phase-out for crude oil price increases provided in section 43(b) of the Code. |
| Notice 2006-61(HTML) |
IRB #2006-29(HTML) |
July 17, 2006 |
| 2006 marginal production rates. This notice announces the applicable percentage under section 613A of the Code to be used in determining percentage depletion for marginal properties for the 2006 calendar year. |
| Notice 2006-60(HTML) |
IRB #2006-29(HTML) |
July 17, 2006 |
| This notice announces that the Treasury Department and IRS will amend regulations section 1.45D-1 to provide guidance on how an entity meets the requirements to be a qualified active low-income community business when its activities involve certain targeted populations under section 45D(e)(2) of the Code. Comments related to section 45D(e)(2) and this notice must be received on or before August 31, 2006. |
| Notice 2006-59(HTML) |
IRB #2006-28(HTML) |
July 10, 2006 |
| Disaster leave-sharing plans. This notice describes certain leave-sharing plans under which employees may deposit leave in an employer-sponsored leave bank for use by other employees who have been adversely affected by a major disaster. For a plan that meets the requirements of this notice, the IRS will not assert that an employee who deposits leave under the plan realizes income or has wages or compensation with respect to the deposited leave, provided the plan treats payments made by the employer to a leave recipient as wages and compensation. No deduction is allowed to an employee who deposits leave. |
| Notice 2006-58(HTML) |
IRB #2006-28(HTML) |
July 10, 2006 |
| This notice provides that the Service will not treat a hotel, motel, or other establishment that otherwise satisfies the definition of "lodging facility" under section 856(d)(9) of the Code as other than a "lodging facility" if it is used to provide temporary housing to certain persons affected by Hurricane Katrina or Hurricane Rita, provided the requirements of the notice are satisfied. |
| Notice 2006-57(HTML) |
IRB #2006-27(HTML) |
July 3, 2006 |
| This notice postpones until October 16, 2006, the due date for filing Form 8898, Statement for Individuals Who Begin or End Bona Fide Residence in a U.S. Possession, for tax years 2001 through 2005. |
| Notice 2006-56(HTML) |
IRB #2006-28(HTML) |
July 10, 2006 |
| This notice supplements and modifies Notice 2006-20, 2006-10 I.R.B. 560, which, under the authority of section 7508A of the Code, postponed until August 28, 2006, deadlines for certain taxpayers affected by Hurricane Katrina. Specifically, this notice provides an additional postponement of time until October 16, 2006, for certain affected taxpayers. |
| Notice 2006-55(HTML) |
IRB #2006-25(HTML) |
June 19, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for June 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-54(HTML) |
IRB #2006-26(HTML) |
June 26, 2006 |
| This notice provides procedures that a vehicle manufacturer (or, in the case of a foreign vehicle manufacturer, its domestic distributor) may use to certify that both a particular make, model, and year of vehicle qualifies as an alternative fuel motor vehicle under sections 30B(a)(4) and (e) of the Code and the amount of the credit allowable with respect to the vehicle. The notice also provides guidance to taxpayers who purchase vehicles regarding the conditions under which they may rely on the vehicle manufacturer's certification. |
| Notice 2006-53(HTML) |
IRB #2006-26(HTML) |
June 26, 2006 |
| This notice modifies section 4.04 of Notice 2006-26, 2006-11 I.R.B. 622, to make clear that a component that provides structural support or a finished surface, or a component that has as a principal purpose any function unrelated to the reduction of heat loss or gain, is not a component specifically and primarily designed to reduce heat loss or gain of a dwelling. Notice 2006-26 clarified. |
| Notice 2006-52(HTML) |
IRB #2006-26(HTML) |
June 26, 2006 |
| This notice sets forth a process that allows a taxpayer who owns a commercial building and installs property as part of the commercial building's interior lighting systems, heating, cooling, ventilation, and hot water systems, or building envelope to obtain a certification that the property satisfies the energy efficiency requirements of section 179D(c)(1) and (d) of the Code. The notice also provides for a public list of software programs that may be used in calculating energy and power consumption for purposes of section 179D. |
| Notice 2006-51(HTML) |
IRB #2006-25(HTML) |
June 19, 2006 |
| Renewable electricity production and refined coal production; calendar year 2006 inflation adjustment factor and reference prices. This notice announces the calendar year 2006 inflation adjustment factor and reference prices for the renewable electricity production credit and refined coal production credit under section 45 of the Code. |
| Notice 2006-50(HTML) |
IRB #2006-25(HTML) |
June 19, 2006 |
| This notice announces that the Service will follow the holding of Am. Bankers Ins. Group v. United States, 408 F.3d 1328 (11th Cir. 2005). The notice provides related guidance to taxpayers and collectors. Notice 2005-79 revoked. |
| Notice 2006-49(HTML) |
IRB #2006-22(HTML) |
May 30, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for May 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-48(HTML) |
IRB #2006-21(HTML) |
May 22, 2006 |
| This notice provides guidance relating to amendments made by section 415 of the American Jobs Creation Act of 2004 (AJCA), which affect the treatment of certain income and assets related to the leasing of aircraft or vessels in foreign commerce. The Treasury Department and the Service intend to amend the regulations under sections 367(a), 954, and 956 to address the amendments made by section 415 of the AJCA and this notice. Until regulations reflecting these changes are issued, taxpayers may rely upon this notice. This notice also solicits comments on whether any other changes to the regulations under sections 367, 954, and 956 are necessary to implement the purposes of section 415 of the AJCA. |
| Notice 2006-47(HTML) |
IRB #2006-20(HTML) |
May 15, 2006 |
| This notice provides a brief description of various elections that were created by the American Jobs Creation Act of 2004 as well as the revocation of certain elections, and it includes information about the effective date, the deadline for making the election/revocation, and interim guidance where applicable. Rev. Proc. 2002-9 modified and amplified. |
| Notice 2006-46(HTML) |
IRB #2006-24(HTML) |
June 12, 2006 |
| This notice announces that the IRS and Treasury intend to issue final regulations under sections 897(d) and (e) of the Code, which will revise the current rules under temporary regulations sections 1.897-5T and 1.897-6T and Notice 89-85, 1989-2 C.B. 403. When finalized, regulations will revise temporary regulations section 1.897-5T(c)(4) to take into account inbound statutory mergers and consolidations described in section 368(a)(1)(A). The regulations will also revise the rules of temporary regulations section 1.897-6T(b)(1) to take into account foreign-to-foreign statutory mergers and consolidations described in section 368(a)(1)(A) and to create two new exceptions to gain recognition under section 1.897-6(b)(1) for certain foreign-to-foreign asset reorganizations. The regulations will also revise the stock disposition rule of temporary regulations section 1.897-6T(b)(1)(iii) and eliminate the conditions specified for nonrecognition in temporary regulations section 1.897-6T(b)(2). Lastly, the regulations will modify the period that must be considered for imposing taxes and accrued interest on prior dispositions of the stock of foreign corporations. Notice 89-85 amplified. |
| Notice 2006-45(HTML) |
IRB #2006-20(HTML) |
May 15, 2006 |
| This notice provides guidance to issuers of state and local bonds on "qualified highway or surface freight transfer facilities" under section 142(a)(15) of the Code. It provides that a project receiving an allocation from the Department of Transportation of a portion of the $15 billion national limitation for qualified highway or surface freight transfer facilities will be treated as meeting the definition of qualified highway or surface freight transfer facilities. It also provides guidance to issuers on how to meet the information reporting requirements. |
| Notice 2006-44(HTML) |
IRB #2006-20(HTML) |
May 15, 2006 |
| Sample; discretionary amendment; Roth section 401(k) plan. This notice provides a sample plan amendment for sponsors, practitioners, and employers (plan sponsors) who want to provide for designated Roth contributions in their section 401(k) plans. The sample amendment will help those plan sponsors comply with the requirement to timely adopt a discretionary amendment by the end of the plan year in which the amendment is effective. |
| Notice 2006-43(HTML) |
IRB #2006-21(HTML) |
May 22, 2006 |
| This notice announces that the Treasury Department and the Service will amend the regulations under section 883 of the Code. The regulations exclude from gross income the income derived from the international operation of a ship or ships or aircraft by a corporation organized in a foreign country that grants an equivalent exemption to U.S. corporations. To receive this benefit, a foreign corporation must also satisfy one of three ownership tests. One such test applies to a controlled foreign corporation (CFC), as defined in section 957(a). To satisfy the CFC ownership test, section 1.883-3(a) requires a CFC to meet an "income inclusion test," as defined in section 1.883-3(b). After the repeal of section 954(a)(4) and (f) (foreign base company shipping income provisions) by the American Jobs Creation Act (AJCA), it is unclear how to apply the income inclusion test. This notice announces that Treasury and the IRS will amend section 1.883-3(b) in light of the repeal of section 954(a) and (f) and provide a new "qualified U.S. person ownership test" that is clear and simple to apply and on which taxpayers may rely until the regulations are amended. |
| Notice 2006-42(HTML) |
IRB #2006-19(HTML) |
May 8, 2006 |
| This notice provides guidance as to the meaning of "gross receipts" for purposes of determining whether small insurance companies qualify as tax exempt under section 501(c)(15) of the Code. |
| Notice 2006-41(HTML) |
IRB #2006-18(HTML) |
May 1, 2006 |
| This notice provides guidance with respect to the information reporting requirements applicable to Gulf Opportunity Zone Bonds, Gulf Opportunity Zone Advance Refunding Bonds, and Gulf Tax Credit Bonds. In addition, the notice provides other guidance with respect to Gulf Tax Credit Bonds including guidance to issuers of Gulf Tax Credit Bonds with respect to the credit rate and arbitrage requirements and guidance to holders of Gulf Tax Credit Bonds with respect to the treatment of the credit for income tax purposes. |
| Notice 2006-40(HTML) |
IRB #2006-18(HTML) |
May 1, 2006 |
| This notice sets forth interim guidance, pending the issuance of regulations, relating to the credit under section 45J of the Code for production of electricity at advanced nuclear power facilities. Specifically, this notice explains the method that will be used to allocate the national megawatt capacity limitation that limits the allowable credit and prescribes the application process by which taxpayers may request an allocation of the national megawatt capacity limitation. This notice also provides guidance on the requirement that the electricity be sold to an unrelated person and on the effect of grants, tax-exempt bonds, subsidized energy financing, and other credits. |
| Notice 2006-39(HTML) |
IRB #2006-17(HTML) |
April 24, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for April 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-38(HTML) |
IRB #2006-16(HTML) |
April 17, 2006 |
| This notice provides relief for persons who have rehabilitation credit property in areas affected by Hurricanes Katrina, Rita, or Wilma. First, the notice provides a safe harbor period of three years for repair of rehabilitation credit property placed in service prior to the hurricanes and damaged by the hurricanes during which time the property is not subject to rehabilitation credit recapture under Code section 50(a)(1) provided that repairs to the property are actively ongoing. Second, for property on which the rehabilitation had begun but has not yet been placed in service on the date that the President declared a major disaster in the area in which the property is located, the running of the 24-month or 60-month period is tolled for a period of 12 months. |
| Notice 2006-37(HTML) |
IRB #2006-18(HTML) |
May 1, 2006 |
| Credit for sales of fuel produced from a nonconventional source, inflation adjustment factor, and reference price. This notice publishes the nonconventional source fuel credit, the inflation adjustment factor, and the reference price under section 29 of the Code for calendar year 2005. This data is used to determine the credit allowable on sales of fuel produced from a nonconventional source. |
| Notice 2006-36(HTML) |
IRB #2006-15(HTML) |
April 10, 2006 |
| Public comments are requested on recommendations for items that should be included on the 2006-2007 Guidance Priority List. Taxpayers may submit recommendations for guidance at any time during the year. Recommendations submitted by May 15, 2006, will be reviewed for possible inclusion on the original 2006-2007 Guidance Priority List. Recommendations received after May 15, 2006, will be reviewed for inclusion in the next periodic update. |
| Notice 2006-35(HTML) |
IRB #2006-14(HTML) |
April 3, 2006 |
| This notice modifies Announcement 2000-48, 2000-1 C.B. 1243, and Notice 2001-43, 2001-2 C.B. 72, by providing that, generally, a branch of a financial institution may not act as a qualified intermediary (QI) after Dec. 31, 2006, in a country that does not have approved know-your-customer (KYC) rules. Announcement 2000-48 and Notice 2001-43 modified. |
| Notice 2006-34(HTML) |
IRB #2006-14(HTML) |
April 3, 2006 |
| The Treasury Department and the Service request information that will be considered in formulating guidance on the income tax treatment of cross licensing arrangements. |
| Notice 2006-33(HTML) |
IRB #2006-15(HTML) |
April 10, 2006 |
| This notice provides transition guidance on the application of section 409A(b) of the Code to outstanding offshore trusts associated with nonqualified deferred compensation, as well as nonqualified deferred compensation arrangements providing that assets will become restricted to the payment of benefits under the plan in connection with a change in the employer's financial health. |
| Notice 2006-32(HTML) |
IRB #2006-13(HTML) |
March 27, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for March 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-31(HTML) |
IRB #2006-15(HTML) |
April 10, 2006 |
| This notice sets out some of the most common frivolous arguments and schemes that taxpayers use to avoid their tax obligations. It also identifies civil and criminal penalties that the Service may impose against taxpayers who engage in abusive tax-avoidance schemes. Notice 2005-30 modified and superseded. |
| Notice 2006-30(HTML) |
IRB #2006-24(HTML) |
June 12, 2006 |
| This notice informs trustees and middlemen of non-mortgage widely held fixed investment trusts (NMWHFITs) that the date for satisfying the qualified NMWHFIT exception in regulations section 1.671-5(c)(2)(iv)(E) is extended by 60 days. |
| Notice 2006-29(HTML) |
IRB #2006-12(HTML) |
March 20, 2006 |
| This notice informs taxpayers of amendments that will be made to the final regulations (T.D. 9241, 2006-7 I.R.B. 427) under section 671 of the Code regarding certain reporting rules for non-mortgage widely held fixed investment trusts (NMWHFITs). Until such amendments reflecting these changes are issued, taxpayers may rely on this notice. |
| Notice 2006-28(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| This notice provides a procedure that an eligible contractor may follow to certify that a manufactured home is an energy efficient home that satisfies the requirements of section 45L(c)(2) or (3) of the Code. |
| Notice 2006-27(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| This notice provides a procedure that an eligible contractor may follow to certify that a dwelling unit, other than a manufactured home, is an energy efficient home that satisfies the requirements of sections 45L(c)(1)(A) and (B) of the Code. |
| Notice 2006-26(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| This notice provides procedures that manufacturers may follow to certify property as either an Eligible Building Envelope Component or Qualified Energy Property, as well as guidance regarding the conditions under which taxpayers seeking to claim the section 25C nonbusiness energy property credit may rely on a manufacturer’s certification. |
| Notice 2006-25(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| This notice establishes the qualifying gasification project program under section 48B of the Code. |
| Notice 2006-24(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| This notice establishes the qualifying advanced coal project program under section 48A of the Code. |
| Notice 2006-23(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| Because Patriot’s Day falls on Monday, April 17, this notice provides individual taxpayers residing in Maine, Maryland, Massachusetts, New Hampshire, New York, Vermont, and the District of Columbia an additional day to file their federal income tax returns and make their payments (until April 18, 2006). This includes the payment of the first installment of estimated tax for 2007. |
| Notice 2006-22(HTML) |
IRB #2006-11(HTML) |
March 13, 2006 |
| Low-income housing tax credit; private activity bonds. Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas are provided for purposes of determining the 2006 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k)(5). |
| Notice 2006-21(HTML) |
IRB #2006-12(HTML) |
March 20, 2006 |
| This notice informs Alabama, Louisiana, and Mississippi of their state population portion in the Gulf Opportunity Zone required to determine the (1) Gulf Opportunity housing amount under section 1400N(c)(1)(B) of the Code, and (2) maximum aggregate face amount of qualified Gulf Opportunity Zone Bonds under section 1400N(a)(3) of the Code. |
| Notice 2006-20(HTML) |
IRB #2006-10(HTML) |
March 6, 2006 |
| This notice supplements Notice 2005-73, 2005-42 I.R.B. 723, News Release IR-2005-112, Notice 2005-81, 2005-47 I.R.B. 977, and Notice 2005-66, 2005-40 I.R.B. 620, which, under the authority of section 7508A, postponed until February 28, 2006, deadlines for certain taxpayers affected by Hurricane Katrina to perform the acts described in Notice 2005-73 (e.g., filing returns and other documents, payment of taxes), and for the Internal Revenue Service (IRS) to perform the acts described in Notice 2005-81 (e.g., assessment, collection). The notice further postpones those deadlines through August 28, 2006, for the IRS and for affected taxpayers in the parishes in Louisiana and the counties in Mississippi and Alabama that the Federal Emergency Management Agency (FEMA) determined were eligible for individual assistance. Notices 2005-66, 2005-73, and 2005-81 supplemented. |
| Notice 2006-19(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for February 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-18(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| The recomputed differential earnings rate for 2004 is tentatively determined for use by mutual life insurance companies to compute their income tax liability for 2005. |
| Notice 2006-17(HTML) |
IRB #2006-10(HTML) |
March 6, 2006 |
| This notice states that the deadline to make an election under section 165(i) of the Code to deduct in the preceding taxable year certain losses attributable to Hurricane Katrina, Rita, or Wilma is postponed until October 16, 2006. |
| Notice 2006-16(HTML) |
IRB #2006-09(HTML) |
February 27, 2006 |
| This notice provides examples of transactions that are not the same or substantially similar to those in Notice 2002-35 (i.e., are not “listed transactions”), such that the filing of Form 8886, Reportable Transaction Disclosure Statement, is not required. Further, for taxpayers who would be required to file a Form 8886 for transactions that are the same or substantially similar as those described in Notice 2002-35 solely as a result of the taxpayers’ interest in a pass-through entity, this notice creates a disclosure requirement safe harbor. Notice 2002-35 clarified and modified. |
| Notice 2006-15(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| Until further guidance is issued, the Service will disregard a spousal right of election for purposes of determining whether a charitable remainder annuity trust (CRAT) or charitable remainder unitrust (CRUT) meets the requirements of section 664(d)(1)(B) or (d)(2)(B) of the Code, provided that the right of election is not exercised. Rev. Proc. 2005-24 modified. |
| Notice 2006-14(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| This notice invites public comments on certain distributions treated as sales or exchanges under section 751(b) of the Code. The Treasury Department and the Service are conducting a study of the current section 751(b) regulations and are considering alternative approaches to achieving the purpose of the statute. |
| Notice 2006-13(HTML) |
IRB #2006-08(HTML) |
February 21, 2006 |
| This notice announces that the IRS and Treasury intend to issue final regulations under section 1503(d) of the Code to provide that a reasonable cause standard similar to proposed regulations section 1.1503(d)-1(c)(1) will apply to cure all late filings under section 1503(d). Prior to issuance of those regulations, taxpayers may rely on the reasonable cause procedure set forth in proposed regulations section 1.1503(d)-1(c)(1), as modified by this notice, to cure late filings under the current regulations. Additionally, until the final regulations are issued, taxpayers may choose to apply for relief for untimely section 1503(d) filings under the provisions of regulations sections 301.9100-1 through 301.9100-3 or elect to use the reasonable cause standard set forth in the proposed regulations as modified by this notice. |
| Notice 2006-12(HTML) |
IRB #2006-07(HTML) |
February 13, 2006 |
| This notice supplements the relief previously granted by the IRS with respect to taxpayers affected by Hurricanes Katrina and Rita. It provides relief from certain backup withholding obligations under section 3406 of the Code due to notification that a payee’s taxpayer identification number is incorrect. Pursuant to the authority of section 7508A, the IRS postpones the time for certain payors to send notices to payees, and to begin imposing backup withholding on reportable payments to such payees. |
| Notice 2006-11(HTML) |
IRB #2006-05(HTML) |
February 13, 2006 |
| The Service is suspending certain requirements under section 42 of the Code for low-income housing credit projects in the United States as a result of the devastation caused by Hurricane Rita. |
| Notice 2006-10(HTML) |
IRB #2006-05(HTML) |
January 30, 2006 |
| Hurricane Katrina evacuation allowances. This notice discusses the income and employment tax treatment of special allowances paid by federal executive agencies to employees and their dependents to reimburse certain expenses incurred while evacuating from the Hurricane Katrina core disaster area and staying at a safe haven. |
| Notice 2006-09(HTML) |
IRB #2006-06(HTML) |
February 6, 2006 |
| This notice provides procedures for a vehicle manufacturer to certify that a passenger automobile or light truck meets certain requirements for the new advanced lean burn technology motor vehicle credit or the new qualified hybrid motor vehicle credit, and to certify the amount of the credit available with respect to the vehicle. The notice also provides guidance to taxpayers who purchase passenger automobiles and light trucks regarding the conditions under which they may rely on the vehicle manufacturer’s certification. |
| Notice 2006-08(HTML) |
IRB #2006-05(HTML) |
January 30, 2006 |
| Weighted average interest rate update; 30-year Treasury securities. The weighted average interest rate for January 2006 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth. |
| Notice 2006-07(HTML) |
IRB #2006-10(HTML) |
March 6, 2006 |
| This notice, which supplements Notice 2005-98, 2005-52 I.R.B. 1211, provides guidance with respect to facilities that may be financed with the proceeds of clean renewable energy bonds under section 54(a) of the Code. In addition, the notice provides guidance with respect to the entities that may own facilities financed with the proceeds of clean renewable energy bonds and the entities that may issue clean renewable energy bonds. Notice 2005-98 supplemented. |
| Notice 2006-06(HTML) |
IRB #2006-05(HTML) |
January 30, 2006 |
| This document notifies taxpayers and material advisors of a future change to the categories of reportable transactions under proposed section 1.6011-4 of the regulations. The Service and Treasury Department will be issuing temporary and proposed regulations under section 1.6011-4 that will remove from the categories of reportable transactions under section 1.6011-4(b)(1) the category of transactions with a significant book-tax difference currently set forth in section 1.6011-4(b)(6). Until the amended regulations are issued, taxpayers and material advisors may rely on this notice. |
| Notice 2006-05(HTML) |
IRB #2006-04(HTML) |
January 23, 2006 |
| This notice provides information to payees/filers who receive payments of interest on qualified education loans who are unable to comply with the reporting requirements for loan origination fees and capitalized interest under section 6050S of the Code and the regulations for calendar year 2005 returns. The notice explains that a payee/filer who is unable to comply with the reporting requirements for loan origination fees and capitalized interest may request that the Service waive, upon a showing of reasonable cause under section 6724 and the regulations, any penalty that might otherwise be imposed under sections 6721 or 6722 for failure to report these amounts. |
| Notice 2006-04(HTML) |
IRB #2006-03(HTML) |
January 17, 2006 |
| This notice addresses the application of section 409A of the Code to outstanding stock rights and specifically the determination, for purposes of the exclusion from coverage under section 409A for certain stock rights, of whether a stock right has an exercise price equal to or greater than the fair market value of the underlying stock at the date of grant. For stock rights issued before January 1, 2005, the notice provides that the determination will be made in accordance with the rules governing incentive stock options. For stock rights issued on or after January 1, 2005, but before the effective date of final regulations, the notice reiterates the standard set forth in Notice 2005-1 that the determination of fair market value may be made using any reasonable valuation method. |
| Notice 2006-03(HTML) |
IRB #2006-03(HTML) |
January 17, 2006 |
| Section 1(h) of the Code provides that certain dividends paid to an individual shareholder from either a domestic corporation or a “qualified foreign corporation” are subject to tax at the reduced rates applicable to certain capital gains. This notice provides guidance for persons required to make returns and provide statements under section 6042 regarding distributions with respect to securities issued by a foreign corporation, and for individuals receiving such statements. This notice provides generally that the simplified procedures and other rules contained in Notice 2003-79 and Notice 2004-71 are extended to apply for 2005 information reporting of distributions with respect to securities issued by foreign corporations and for future years. |
| Notice 2006-02(HTML) |
IRB #2006-02(HTML) |
January 9, 2006 |
| Extension of transition relief for certain partnerships and other pass-thru entities under section 470. This notice extends the transition relief under section 470 of the Code provided under Notice 2005-29, 2005-13 I.R.B. 796, to partnerships and certain other pass-thru entities that are treated as holding tax-exempt use property because of the application of section 168(h)(6), to taxable years that begin before January 1, 2006. Notice 2005-29 modified and superseded. |
| Notice 2006-01(HTML) |
IRB #2006-04(HTML) |
January 23, 2006 |
| Information reporting by organizations that receive contributions of qualified vehicles. This notice provides guidance to donee organizations that receive contributions of qualified vehicles on their reporting obligations under section 170(f)(12)(D) of the Code. It instructs the donee organization on how, where, and when to report to the IRS the information contained in the contemporaneous written acknowledgment that the donee organization provides to the donor. Notice 2005-44 supplemented. |
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