Internal Revenue Bulletin: 2006-49
December 4, 2006
Final and temporary regulations under sections 6011, 6111, and 6112 of the Code amend the rules relating to requests for private letter rulings regarding reportable transactions and remove the tolling provision from the current regulations. These regulations cross-reference REG-103038-05, REG-103039-05, and REG-103043-05 in this Bulletin.
Proposed regulations under section 6111 of the Code provide the rules relating to the disclosure of reportable transactions by material advisors. These regulations cross-reference T.D. 9295 in this Bulletin.
Proposed regulations under section 6112 of the Code provide the rules relating to the obligation of material advisors to prepare and maintain lists with respect to reportable transactions. These regulations cross-reference T.D. 9295 in this Bulletin.
This document updates the procedures for requesting assistance from the U.S. competent authority under the provisions of an income, estate, or gift tax treaty to which the United States is a party. Rev. Procs. 2002-52 and 2006-26 modified and superseded. Rev. Proc. 2006-9 amplified. Rev. Rul. 92-75 clarified.
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