Internal Revenue Bulletin: 2006-20
May 15, 2006
This notice provides a brief description of various elections that were created by the American Jobs Creation Act of 2004 as well as the revocation of certain elections, and it includes information about the effective date, the deadline for making the election/revocation, and interim guidance where applicable. Rev. Proc. 2002-9 modified and amplified.
This document updates the procedures for requesting assistance from the U.S. competent authority under the provisions of tax coordination agreements entered into between the IRS and the tax agencies of American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, the U.S. Virgin Islands, and Puerto Rico (collectively, the U.S. possessions). Rev. Proc. 89-8 superseded.
This announcement contains corrections to T.D. 9244, 2006-8 I.R.B. 463, that provides guidance regarding the determination of the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions.
This announcement contains a correction to final regulations (T.D. 9248, 2006-9 I.R.B. 524) under sections 881(b) and 937(a) of the Code that provide rules for determining bona fide residency in the following U.S. possessions: American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the United States Virgin Islands.
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