Internal Revenue Bulletin:  2006-2 

January 9, 2006 

INCOME TAX


Rev. Rul. 2006-1 Rev. Rul. 2006-1

Regulated investment company (RIC). A RIC's income from a derivative contract with respect to a commodity index is not qualifying income for purposes of section 851(b)(2) of the Code if the income from the contract is not derived with respect to the RIC's business of investing in stocks, securities, or currencies. Such a contract is not a security for purposes of section 851(b)(2).

Rev. Rul. 2006-2 Rev. Rul. 2006-2

Section 351. The conclusion in Rev. Rul. 74-503 that a transferor's basis in transferee stock received in exchange for transferor stock is determined under section 362(a) of the Code is incorrect. The other conclusions in the ruling are under study. Rev. Rul. 74-503 revoked.

Rev. Rul. 2006-3 Rev. Rul. 2006-3

Japanese Yugen Kaisha (YK) and Tokurei Yugen Kaisha (TYK). A Yugen Kaisha, a Japanese business entity, which will become a Tokurei Yugen Kaisha under recently enacted Japanese legislation, will continue to be eligible to elect its U.S. entity classification under the check the box regulations.

Rev. Rul. 2006-4 Rev. Rul. 2006-4

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 January 2006.

T.D. 9231 T.D. 9231

Final regulations under section 1298 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC.

T.D. 9232 T.D. 9232

Temporary and proposed regulations under section 1297 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC. A public hearing on the proposed regulations is scheduled for March 22, 2006.

REG-133446-03 REG-133446-03

Temporary and proposed regulations under section 1297 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC. A public hearing on the proposed regulations is scheduled for March 22, 2006.

Notice 2006-2 Notice 2006-2

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.

Rev. Proc. 2006-9 Rev. Proc. 2006-9

This procedure explains the manner in which taxpayers may request an advance pricing agreement (APA) from the APA Program within the Office of the Associate Chief Counsel (International), the manner in which such a request will be processed by the APA Program, and the effect and administration of APAs. Rev. Proc. 2004-40 superseded.

Rev. Proc. 2006-10 Rev. Proc. 2006-10

This procedure supersedes Rev. Proc. 96-52, 1996-2 C.B. 372. It describes the qualifications necessary to become an acceptance agent and the procedures that an acceptance agent applicant must follow for purposes of entering into an acceptance agent agreement with the IRS. Rev. Proc. 96-52 superseded.

Announcement 2006-2 Announcement 2006-2

The December 2005 revision of Form 8609, Low-Income Housing Credit Allocation and Certification, contains changes from the previous revision. Form 8609-A, Annual Statement for Low-Income Housing Credit, is replacing Schedule A (Form 8609).


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