Internal Revenue Bulletin:  2006-36 

September 5, 2006 

INCOME TAX


Rev. Rul. 2006-36 Rev. Rul. 2006-36

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 Rev. Rul. 2006-44

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 T.D. 9279

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.

T.D. 9279 REG-125071-06

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 REG-124152-06

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 Notice 2006-72

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 Announcement 2006-61

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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