Internal Revenue Bulletin:  2006-40 

October 2, 2006 

INCOME TAX


Rev. Rul. 2006-49 Rev. Rul. 2006-49

Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 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.

T.D. 9284 T.D. 9284

Final regulations under section 6502 of the Code incorporate changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS’s ability to enter into agreements extending the statute of limitations for collection.

REG-121509-00 REG-121509-00

Proposed regulations under sections 959, 961, and 1502 of the Code provide guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 and related basis adjustments under section 961.

REG-148576-05 REG-148576-05

Proposed regulations under 31 USC 9701 increase the amount of the user fees imposed under regulations sections 300.1 and 300.2 for entering into and restructuring or reinstating installment agreements. The regulations bring the fees in line with the actual costs to the IRS. Currently, the IRS charges $43 for entering into an installment agreement and $24 for restructuring or reinstating an installment agreement that is in default. The IRS recently completed a review of the installment agreement program and determined that the full cost of an installment agreement is $105, and the full cost of restructuring or reinstating an installment agreement is $45. The regulations reflect these costs, with one exception; the fee for entering into an installment agreement paid by way of a direct debit from the taxpayer’s checking account will be $52, to encourage this type of payment arrangement. A public hearing is scheduled for October 17, 2006.

Notice 2006-77 Notice 2006-77

This notice republishes Notice 2006-67, 2006-33 I.R.B. 248, to reflect the citations to the final regulations for the additional first year depreciation deduction provided by section 168(k) of the Code. The notice provides guidance with respect to the 50-percent additional first year depreciation deduction provided by section 1400N(d) of the Code for qualified Gulf Opportunity (GO) Zone property. Notice 2006-67 modified and superseded. Rev. Proc. 2002-9 modified and amplified.

Notice 2006-81 Notice 2006-81

Section 355. This notice provides guidance for making an election under section 355(b)(3)(C) of the Code.

Notice 2006-83 Notice 2006-83

This notice provides guidance to individual chapter 11 debtors and their bankruptcy estates regarding the tax treatment of post-petition income as the result of the enactment of section 1115 of the Bankruptcy Code by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. The notice also alerts information return preparers regarding their reporting responsibilities.

Rev. Proc. 2006-39 Rev. Proc. 2006-39

This procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2004.

Announcement 2006-71 Announcement 2006-71

This document cancels a public hearing on proposed regulations (REG-118775-06, 2006-28 I.R.B. 73) under sections 871 and 881 of the Code relating to the exclusion from gross income of portfolio interest paid to a nonresident alien individual or foreign corporation.

Announcement 2006-72 Announcement 2006-72

This document contains a correction to final regulations (T.D. 9277, 2006-33 I.R.B. 226) providing guidance regarding employer comparable contributions to Health Savings Accounts (HSAs) under section 4980G of the Code.


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