Internal Revenue Bulletin: 2006-25
June 19, 2006
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning July 1, 2006, will be 8 percent for overpayments (7 percent in the case of a corporation), 8 percent for underpayments, and 10 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 5.5 percent.
Regulated investment company (RIC). This ruling modifies Rev. Rul. 2006-1 to extend until September 30, 2006, the transition period provided by that ruling, and clarifies that Rev. Rul. 2006-1 was not intended to preclude a conclusion that income from certain instruments (such as structured notes) that create a commodity exposure for the holder is qualifying income under section 851(b)(2) of the Code. Rev. Rul. 2006-1 modified and clarified.
Final regulations under section 199 of the Code relate to the deduction for income attributable to domestic production activities. Section 199 was enacted as part of the American Jobs Creation Act (AJCA) of 2004, and allows a deduction equal to 3 percent (for 2005 and 2006) of the lesser of the qualified production activities income of the taxpayer for the taxable year, or the taxable income of the taxpayer for the taxable year, subject to certain limits. The applicable percentage rises to 6 percent for 2007, 2008, and 2009, and 9 percent for 2010 and subsequent years. Notice 2005-14 obsoleted for taxable years beginning on or after June 1, 2006.
Renewable electricity production and refined coal production; calendar year 2006 inflation adjustment factor and reference prices. This notice announces the calendar year 2006 inflation adjustment factor and reference prices for the renewable electricity production credit and refined coal production credit under section 45 of the Code.
Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individuals from meeting those requirements. A list of the country for tax year 2005 and the date that country is subject to the section 911(d)(4) waiver is provided.
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