Internal Revenue Bulletin: 2006-47
November 20, 2006
Table of Contents
Qualified transportation fringes; smartcards and debit cards. This ruling provides guidance to employers on the use of smartcards and debit cards to provide qualified transportation fringes under section 132(f) of the Code.
Final regulations under section 704 of the Code provide that allocations of creditable foreign tax expenditures cannot have substantial economic effect, and, therefore, must be allocated in accordance with the partners’ interests in the partnership. The regulations provide a safe harbor whereby allocations of creditable foreign tax expenditures will be deemed to be in accordance with the partners’ interests in the partnership. To satisfy the safe harbor, allocations of creditable foreign tax expenditures must be in proportion to the distributive shares of income to which the taxes relate.
Proposed regulations under section 72 of the Code provide guidance on taxation of the exchange of property for an annuity contract. The regulations would apply the same rule to exchanges for both private annuities and commercial annuities, but the regulations would not affect charitable gift annuities. A public hearing is scheduled for February 16, 2007.
Proposed regulations under section 141 of the Code provide guidance relating to the standards for treating payments in lieu of taxes as generally applicable taxes for purposes of the private security or payment test. A public hearing is scheduled for February 13, 2007.
This notice updates Notice 2003-69, 2003-2 C.B. 851, which contains a list of the United States tax treaties that meet the requirements of section 1(h)(11)(C)(i)(II) of the Code. Notice 2003-69 amplified and superseded.
This document provides rules for taxpayers to obtain automatic approval to change certain elections to apportion interest expense and research and experimentation expense under section 861 of the Code as a result of new rules under the section 199 domestic production activities deduction.
This procedure amplifies Rev. Proc. 2005-70, 2005-47 I.R.B. 979, to provide the maximum amount of foreign earned income, as adjusted for inflation, that may be excluded from gross income under section 911 of the Code for taxable years beginning in 2006. Rev. Proc. 2005-70 amplified.
|More Internal Revenue Bulletins|