Internal Revenue Bulletin: 2006-12
March 20, 2006
TEFRA partnership provisions; classification of items. This ruling provides that the tax treatment by an affiliated group on a consolidated return of the parent corporation’s payment to a partnership, in which the parent is not a partner, is not a “partnership item” within the meaning of section 6231(a)(3) of the Code or an “affected item” within the meaning of section 6231(a)(5), even if another member of the group is a partner in the partnership.
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning April 1, 2006, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.
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.
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.
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