Internal Revenue Bulletin: 2006-14
April 3, 2006
Table of Contents
Sale of seized real property by IRS; federal tax delinquency. The Supreme Court holds that the national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal-question jurisdiction over the disputed issue on removal. Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing.
Joint and several liability; relief under section 6015. This ruling discusses the issue of whether a taxpayer is precluded from raising a request for relief from joint and several liability under section 6015 by virtue of a previous Chapter 7 bankruptcy case in which the Service filed a proof of claim, but the bankruptcy court did not make an actual determination of tax liability.
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 April 2006.
Final regulations under section 6103(j) of the Code incorporate and clarify the phrase “return information reflected on returns” in conformance with the terms of section 6103(j)(5), which provides for limited disclosures of returns and return information in connection with the census of agriculture.
The Treasury Department and the IRS issued comprehensive withholding and reporting regulations (T.D. 8734 and T.D. 8881) that became effective on January 1, 2001. In Notice 2001-4, 2001-1 C.B. 267; Notice 2001-11, 2001-1 C.B. 464; and Notice 2001-43, 2001-2 C.B. 72; the Treasury Department and the IRS announced the intention to amend the final regulations. These final regulations implement certain changes announced in those notices and other changes. In addition, these final regulations provide guidance under section 411 of the American Jobs Act of 2004. Notice 2001-11 and certain sections of Notices 2001-4 and 2001-43 superseded.
The Treasury Department and the Service request information that will be considered in formulating guidance on the income tax treatment of cross licensing arrangements.
This notice modifies Announcement 2000-48, 2000-1 C.B. 1243, and Notice 2001-43, 2001-2 C.B. 72, by providing that, generally, a branch of a financial institution may not act as a qualified intermediary (QI) after December 31, 2006, in a country that does not have approved know-your-customer (KYC) rules. Announcement 2000-48 and Notice 2001-43 modified.
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