INCOME TAX

T.D. 9271(HTML)
Final regulations under section 338 of the Code provide that the step transaction doctrine will not be applied if a taxpayer makes a valid section 338(h)(10) election with respect to a step in a multi-step transaction, even if the transaction would otherwise qualify as a reorganization if the step standing alone is a qualified stock purchase.

T.D. 9277(HTML)
Final regulations under section 4980G of the Code provide guidance regarding employer comparable contributions to Health Savings Accounts (HSAs). The regulations provide that if an employer makes comparable contributions to any employee's HSA, the employer must make comparable contributions for the calendar year to the HSAs of all comparable participating employees. In addition, the final regulations set forth the rules for calculating comparable contributions.

Notice 2006-67(HTML)
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 2006-70(HTML)
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 December 28, 2005.

Announcement 2006-54(HTML)
Nationwide Consumer Credit Services of Ft. Lauderdale, FL, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

EXCISE TAX

T.D. 9277(HTML)
Final regulations under section 4980G of the Code provide guidance regarding employer comparable contributions to Health Savings Accounts (HSAs). The regulations provide that if an employer makes comparable contributions to any employee's HSA, the employer must make comparable contributions for the calendar year to the HSAs of all comparable participating employees. In addition, the final regulations set forth the rules for calculating comparable contributions.

T.D. 9270(HTML)
Final regulations under section 6045(f) of the code relate to information reporting for payments of gross proceeds to attorneys. Regulations under section 6041 are also amended with respect to information reporting for payments for legal services.

T.D. 9274(HTML)
Final regulations under section 6103 of the Code describe the circumstances under which IRS and the Office of Treasury Inspector General for Tax Administration (TIGTA) employees may disclose return information for investigative purposes. The regulations clarify and elaborate on the types of situations and contexts in which investigative disclosures may be made.

Announcement 2006-52(HTML)
Change in accounting methods; revised instructions for Form 3115. The instructions for Form 3115 have been revised as of May 2006. The May 2006 version of the instructions for Form 3115 is to be used with the December 2003 version of Form 3115, Application for Change in Accounting Method.

Announcement 2006-53(HTML)
This document provides a change of location for a public hearing on proposed regulations (REG-111578-06, 2006-24 I.R.B. 1060) under section 199 of the Code. The regulations provide a deduction for income attributable to domestic production activities to certain transactions involving computer software. The public hearing is scheduled for August 29, 2006.