INCOME TAX

T.D. 9234(HTML)
Final regulations under section 141 of the Code provide rules in regulations section 1.141-13 for the application of the private activity bond tests to bonds issued to refund prior bonds. Section 1.141-13 was previously reserved when the comprehensive private activity bonds were released in 1997. The regulations will generally be effective on the date they are published in the Federal Register.

T.D. 9235(HTML)
Final and temporary regulations under section 7701 of the Code make additions to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification.

REG-107722-00(HTML)
Proposed regulations under section 6655 of the Code provide guidance to corporations on the requirements to make estimated tax payments and withdraw proposed regulations under section 6655 that the Service issued in 1984. These regulations reflect changes to the law since 1984 and address abuses that are inherent in the current regulations. A public hearing is scheduled for March 15, 2006.

Notice 2006-01(HTML)
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.

Rev. Proc. 2006-14(HTML)
Use of replacement cost method to value parts inventory of heavy equipment dealers. Heavy equipment dealers may approximate the cost of their heavy equipment parts inventory using the safe harbor replacement cost method described in this revenue procedure. Procedures are provided for heavy equipment dealers to obtain the automatic consent of the Commissioner to change to this replacement cost method of accounting. Rev. Proc. 2002-9 modified and amplified. Rev. Proc. 2002-17 modified.

Notice 2006-01(HTML)
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.

Announcement 2006-05(HTML)
A list is provided of organizations now classified as private foundations.

TAX CONVENTIONS

Announcement 2006-06(HTML)
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.

Announcement 2006-07(HTML)
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 2006-08(HTML)
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.

T.D. 9235(HTML)
Final and temporary regulations under section 7701 of the Code make additions to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification.

Notice 2006-05(HTML)
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.

Rev. Proc. 2006-14(HTML)
Use of replacement cost method to value parts inventory of heavy equipment dealers. Heavy equipment dealers may approximate the cost of their heavy equipment parts inventory using the safe harbor replacement cost method described in this revenue procedure. Procedures are provided for heavy equipment dealers to obtain the automatic consent of the Commissioner to change to this replacement cost method of accounting. Rev. Proc. 2002-9 modified and amplified. Rev. Proc. 2002-17 modified.