Internal Revenue Bulletin No. 2006-36, September 5, 2006
Internal Revenue Bulletins  
September 5, 2006

Internal Revenue Bulletin No. 2006-36

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INCOME TAX

Rev. Rul. 2006-36(HTML)
Health reimbursement arrangements. This ruling holds that amounts that may be paid as medical benefits to a designated beneficiary (other than an employee's spouse or an employee's dependent) are not excludable from the employee's gross income under section 105(b) of the Code. Notice 2002-45 and Rev. Ruls. 2002-41 and 2005-24 amplified.

Rev. Rul. 2006-44(HTML)
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long- term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2006.

T.D. 9279(HTML)
REG-125071-06(HTML)
Final, temporary, and proposed regulations under section 671 of the Code amend regulations section 1.671-5, reporting rules for widely held fixed investment trusts (WHFITs), to clarify and simplify the application of those rules to non-mortgage widely held fixed investment trusts (NMWHFITs). The proposed regulations also include a requirement that trustees of WHFITs file an information return with the IRS and provide for the IRS to create a directory of NMWHFITs and trustees of widely held mortgage trusts (WHMTs). The proposed regulations clarify the market discount reporting rules under the NMWHFIT safe harbor and solicit comments on the WHMT safe harbor.

REG-124152-06(HTML)
Proposed regulations provide guidance relating to the determination of who is considered to pay a foreign tax for purposes of sections 901 and 903 of the Code. A public hearing is scheduled for October 13, 2006.

Notice 2006-72(HTML)
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.

Announcement 2006-61(HTML)
This announcement provides an opportunity for small business/ self employed taxpayers to use Fast Track Settlement (FTS) to expedite case resolution within the IRS's Small Business/ Self Employed (SB/SE) organization. The SB/SE FTS will enable SB/SE taxpayers that currently have unagreed issues in at least one open year under examination to work together with SB/SE and the Office of Appeals to resolve outstanding disputed issues while the case is still in SB/SE jurisdiction.

EMPLOYEE PLANS

Notice 2006-75(HTML)
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.

EXEMPT ORGANIZATIONS

Announcement 2006-60(HTML)
Aylesi M. Bobo Charitable Foundation of Independence, MO, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

ADMINISTRATIVE

Notice 2006-72(HTML)
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.

Announcement 2006-58(HTML)
This document provides changes of date and location for a public hearing on proposed regulations (REG-118775-06, 2006-28 I.R.B. 73) under sections 871 and 881 of the Code relating to the exclusion from gross income of portfolio interest paid to a nonresident alien individual or foreign corporation. The public hearing is rescheduled for October 6, 2006.

Announcement 2006-59(HTML)
Bonds issued by or on behalf of Indian tribal governments are excluded from gross income only if the proceeds of such bonds are used for an "essential governmental function." This announcement of advanced notice of proposed rulemaking provides that an activity performed by an Indian tribal government will be treated as an essential governmental function if (1) many state and local governments conduct such activity and finance it with tax-exempt bonds, (2) state and local governments have been financing such activity for many years, and (3) such activity is not a commercial or industrial activity.

Announcement 2006-61(HTML)
This announcement provides an opportunity for small business/ self employed taxpayers to use Fast Track Settlement (FTS) to expedite case resolution within the IRS's Small Business/ Self Employed (SB/SE) organization. The SB/SE FTS will enable SB/SE taxpayers that currently have unagreed issues in at least one open year under examination to work together with SB/SE and the Office of Appeals to resolve outstanding disputed issues while the case is still in SB/SE jurisdiction.

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