To obtain a copy of any of these issues, please send an e-mail to the US-KPMG Washington National Tax.
December 2006
Issue |
Date |
Subject |
2006-366 |
December 29, 2006 |
IRS Issues Procedures for Large and Mid-Size Business Pre-Filing Agreements |
2006-365 |
December 29, 2006 |
IRS Issues an Automatic Consent Procedure for Change in Method of Accounting for Depreciable or Amortizable Property After its Disposition |
2006-364 |
December 29, 2006 |
IRS Issues Additional Guidance on Taxpayer Requests for Credit or Refund of Excise Tax on Long-Distance Telephone Services |
2006-363 |
December 27, 2006 |
Text of Final Regulations Concerning Reporting Rules for Widely Held Investment Trusts |
2006-362 |
December 27, 2006 |
Text of Final Regulations on the Source of Income from Certain Space and Ocean Activities, and Communication Activities |
2006-361 |
December 22, 2006 |
IRS Moves to Implement Recently Enacted Extenders Provisions Affecting Individual Taxpayers |
2006-360 |
December 22, 2006 |
IRS Adds Bulgarian Entity to List of Per Se Corporations |
2006-359 |
December 22, 2006 |
IRS Reports Ford and Mercury Hybrids Continue to Qualify for Alternative Motor Vehicle Credit |
2006-358 |
December 22, 2006 |
Final Regulations Issued on Accounting Method Changes for Depreciation |
2006-357 |
December 21, 2006 |
Protocols to United States-France Income Tax and Estate Tax Treaties Enter into Force |
2006-356 |
December 21, 2006 |
OECD Releases Updated Report on Attribution of Profits to Permanent Establishments |
2006-355 |
December 21, 2006 |
IRS Lifts Moratorium and Will Begin Processing Suspended Cash Balance Plan Conversion Applications |
2006-354 |
December 21, 2006 |
Text of Regulations Affecting Members of Controlled Groups, Consolidated Groups Filing Life-Nonlife Federal Income Tax Returns |
2006-353 |
December 21, 2006 |
IRS Rules Execution of a Contract for Services or Insurance Does Not Establish Fact of the Liability; Issues Automatic Consent Procedures to Comply with Ruling |
2006-352 |
December 20, 2006 |
Legislative Update: President Bush Signs Tax Bill with Extender, Energy, and Trade Provisions |
2006-351 |
December 20, 2006 |
Text of IRS Guidance Relating to Controlled Services Transactions and Services Cost Method Under Section 482 |
2006-350 |
December 19, 2006 |
Text of Final Regulations on ESOPs Holding Stock of S Corporations, and Prohibited Allocations of S Corporation Stock Under Section 409(p) |
2006-349 |
December 18, 2006 |
Reg. Section 1.882-5 Deductible Interest Expense and Reg. Section 1.884-1(e)(3) Branch Profits Tax: Certain Foreign Corporations May Elect to Apply T.D. 9281 to Earlier Tax Period Than Originally Allowed |
2006-348 |
December 18, 2006 |
Regulations Address Circumstances Under Which Section 354 Distribution Requirement Is Satisfied for Purposes of Section 368(a)(1)(D) if No Acquiring Stock Is Issued in the Transaction |
2006-347 |
December 18, 2006 |
KPMG’s This Week in State Tax: Developments in Kentucky, Massachusetts, Minnesota, and New Hampshire |
2006-346 |
December 14, 2006 |
IRS Provides 2006 Cumulative List of Changes in Plan Qualification Requirements |
2006-345 |
December 14, 2006 |
IRS Extends Transition Relief to Certain Stores Concerning Customers’ Use of Debit Cards for Medical Expense Reimbursements |
2006-344 |
December 13, 2006 |
IRS Extends Section 470 Transition Relief |
2006-343 |
December 12, 2006 |
Text of Regulations Relating to HIPPA Nondiscrimination Requirements in Certain Grandfathered Church Plans, and Addressing Nondiscrimination and Wellness Programs in Health Coverage |
2006-342 |
December 11, 2006 |
Regulations Relating to Reduction in Taxable Income for Housing Hurricane Katrina Displaced Individuals |
2006-341 |
December 11, 2006 |
Research Tax Credit: Congress Approves a Seamless Extension Through 2007, With Significant Modifications |
2006-340 |
December 11, 2006 |
Legislative Update: Summary (Table Format) of Tax, Energy Provisions in Extenders Bill |
2006-339 |
December 11, 2006 |
KPMG’s This Week in State Tax: Developments in California, Delaware, Indiana, New York, and Virginia |
2006-338 |
December 8, 2006 |
Legislative Update: House Passes Amended Tax Extenders Bill |
2006-337 |
December 8, 2006 |
IRS Announces Reopening of National Office Building, and Return to Normal Procedures for Filing Letter Ruling Requests |
2006-336 |
December 7, 2006 |
Legislative Update: House Prepares to Vote on New Extenders Bill |
2006-335 |
December 6, 2006 |
Legislative Update: Senate Finance Committee Prepares Tax Extenders Bill |
2006-334 |
December 5, 2006 |
IRS Issues Automatic Change Concerning Nonaccrual-Experience Method of Accounting |
2006-333 |
December 4, 2006 |
Treasury Opens Competition for Next Round of New Markets Tax Credits |
2006-332 |
December 4, 2006 |
KPMG’s This Week in State Tax: Developments in Alabama, California, Pennsylvania, Texas, West Virginia and Wisconsin |
November 2006
Issue |
Date |
Subject |
2006-331 |
November 30, 2006 |
IRS Announces $1 Billion in Tax Credits Allocated to Clean Coal Projects |
2006-330 |
November 30, 2006 |
IRS Notice on Reporting, Withholding for Amounts Includible in Gross Income Under Section 409A |
2006-329 |
November 30, 2006 |
IRS Provides Transitional Guidance Relating to Diversification Rules for Qualified Defined Contribution Plans Holding Publicly Traded Employer Securities |
2006-328 |
November 27, 2006 |
United States, Belgium Sign New Income Tax Treaty |
2006-327 |
November 22, 2006 |
IRS Reports Honda Compressed Natural Gas Vehicles and Certain 2007 Hybrids Qualify for Alternative Motor Vehicle Credit |
2006-326 |
November 21, 2006 |
IRS Procedures for Commercial Passenger Airlines to Elect “Alternative Deficit Reduction Contribution” to Pension Plans |
2006-325 |
November 20, 2006 |
IRS Releases Information Concerning Clean Renewable Energy Bond Volume Cap Allocation |
2006-324 |
November 20, 2006 |
Seventh Circuit Affirms Summary Judgment for Taxpayer in Debt-Equity Swap Involving Mexican Pesos |
2006-323 |
November 20, 2006 |
KPMG’s This Week in State Tax: Developments in California, Connecticut, Massachusetts, Pennsylvania and South Carolina |
2006-322 |
November 17, 2006 |
Court of Federal Claims: Taxpayer Entitled to Partial Refund of Federal Communications Excise Tax Paid on Certain Communications Services Used to Provide Internet Access to Customers |
2006-321 |
November 17, 2006 |
IRS Revises Procedures for Requesting Competent Authority Assistance |
2006-320 |
November 17, 2006 |
IRS Announces Settlement Initiative for U.S.-Based Employees of Foreign Embassies and International Organizations |
2006-319 |
November 16, 2006 |
IRS Provides Formula for Businesses to Use in Estimating Their Federal Telephone Excise Tax Refund |
2006-318 |
November 15, 2006 |
IRS Reports Honda Hybrids Continue to Qualify for Alternative Motor Vehicle Credit |
2006-317 |
November 15, 2006 |
Treasury Releases New Versions of U.S. Model Income Tax Convention, Model Technical Explanation |
2006-316 |
November 13, 2006 |
California State Court Again Concludes That California’s LLC Fee Is Unconstitutional |
2006-315 |
November 13, 2006 |
Federal Circuit Affirms Resolution of Reserved Issues in Form 870-AD Terminated Form 872-A |
2006-314 |
November 13, 2006 |
Final Regulations on Residency of Taxpayers in U.S. Possessions Now Allow Three-Year Averaging Alternative to the Presence Test |
2006-313 |
November 13, 2006 |
IRS Clarifies Correct Filing Address for International Businesses |
2006-312 |
November 13, 2006 |
KPMG’s This Week in State Tax: Developments in Alabama, California, Ohio, Oregon and Virginia |
2006-311 |
November 9, 2006 |
IRS Revenue Ruling Addresses Certain Per Diem Expense Reimbursement Arrangements |
2006-310 |
November 9, 2006 |
IRS Announces Certain GM Vehicles Continue to Qualify for Alternative Motor Vehicle Credit, Whereas Credit for Qualifying Toyota and Lexis Hybrids Begins to Phase Out |
2006-309 |
November 9, 2006 |
IRS Announces Inflation Adjustments, Changes in Tax Brackets and Certain Tax Benefits for 2007 |
2006-308 |
November 8, 2006 |
Eighth Circuit Generally Affirms Damages Awarded to Taxpayers for Disclosures of Taxpayer Return Information by IRS Special Agent |
2006-307 |
November 8, 2006 |
IRS Reminds Individual Taxpayers in Certain Eastern States That Patriots’ Day 2007 Will Afford Extra Time to File Returns, Pay Taxes |
2006-306 |
November 8, 2006 |
Text of Final Research Credit Regulations Concerning Method for Computing and Allocating a Credit for Members of a Controlled Group |
2006-305 |
November 7, 2006 |
Tax Court Addresses Treatment of Incentive Stock Options for AMT Purposes |
2006-304 |
November 6, 2006 |
KPMG’s This Week in State Tax: Developments in New York, North Carolina, Tennessee, Virginia and West Virginia |
2006-303 |
November 3, 2006 |
IRS Provides New Foreign Earned Income Exclusion Amount for 2006 |
2006-302 |
November 1, 2006 |
IRS Announces Increased Standard Mileage Allowance of 48.5 Cents Per Mile for 2007 |
2006-301 |
November 1, 2006 |
Text of Regulations Concerning Disclosure of Reportable Transactions and List Maintenance Requirements |
October 2006
Issue |
Date |
Subject |
2006-300 |
October 30, 2006 |
IRS Amends Guidance Relating to Standards for Calculating Energy Savings for “New Energy Efficient Home Credit” |
2006-299 |
October 30, 2006 |
IRS Updates Treaty List for Determining “Qualified Foreign Corporations” That Pay Dividends Eligible for 15% Individual Tax Rate |
2006-298 |
October 30, 2006 |
KPMG’s This Week in State Tax: Developments in Alabama, California, Minnesota, New York and Texas |
2006-297 |
October 27, 2006 |
IRS Issues Guidance Concerning REITs |
2006-296 |
October 27, 2006 |
IRS Announces Changes to Withholding and Information Reporting on Foreign Persons |
2006-295 |
October 23, 2006 |
Tax Court Concludes Ferryboat Captain Not Required to Prorate Expenses for Partial Day of Travel, but Must Reduce Allowable Expenses by 50% |
2006-294 |
October 23, 2006 |
KPMG’s This Week in State Tax: Developments in Georgia, Massachusetts, Michigan, New Jersey, New York, and North Carolina |
2006-293 |
October 20, 2006 |
Additional Ford Vehicles Certified for Alternative Motor Vehicle Credit |
2006-292 |
October 20, 2006 |
Proposed Regulations Concerning Limitations on Transfers or Importation of Built-in Losses |
2006-291 |
October 19, 2006 |
Final Regulations on Electronic Benefit Notices, Elections, and Consents |
2006-290 |
October 18, 2006 |
IRS Updates Procedures for Corporations, Partnerships, S Corporations and Other Entities to Obtain Automatic Approval to Change Annual Accounting Period |
2006-289 |
October 18, 2006 |
IRS Announces Pension Plan Limitation Amounts for 2007 |
2006-288 |
October 18, 2006 |
IRS Implements Appeals Arbitration Program |
2006-287 |
October 18, 2006 |
Text of Final Regulations Concerning Partnership Allocations of Foreign Taxes and Foreign Source Income Affecting Foreign Tax Credits |
2006-286 |
October 18, 2006 |
Text of Temporary Regulations Concerning Changes Made to Section 199 and the Deduction for Income Attributable to Domestic Production Activities |
2006-285 |
October 18, 2006 |
IRS Procedure for Obtaining Automatic Approval to Change Accounting Method to Comply with the Final Regulations on the Bonus Depreciation Deduction |
2006-284 |
October 17, 2006 |
IRS Practice & Procedure Alert: New IRS Initiative Addresses Implications of FIN 48 |
2006-283 |
October 17, 2006 |
IRS Guidance on Methods for Calculating W-2 Wages for Section 199 Purposes |
2006-282 |
October 17, 2006 |
Proposed Regulations to Amend Rules for Exchanges of Annuities |
2006-281 |
October 17, 2006 |
Analysis of Proposed Section 959 and Section 961 Regulations: Updating and Clarifying Rules Relating to Exclusion of Previously Taxed Earnings and Profits and Related Basis Adjustments |
2006-280 |
October 16, 2006 |
KPMG’s This Week in State Tax: Developments in Nebraska, New Jersey, California, and Montana; A Report on State Business Tax Climates |
2006-279 |
October 11, 2006 |
IRS Procedure for Obtaining Automatic Approval to Change Elections Relating to Apportionment of Interest Expense and R&E Expenditures |
2006-278 |
October 11, 2006 |
Analysis of United Kingdom/United States Dual Consolidated Loss Competent Authority Agreement—Re: Mirror Legislation Rule |
2006-277 |
October 10, 2006 |
United Kingdom/United States Dual Consolidated Loss Competent Authority Agreement—Re: Mirror Legislation Rule |
2006-276 |
October 10, 2006 |
Text of Final Regulations Addressing When Partner Bears Economic Risk for Partnership Loss Based on Disregarded Entity’s Obligation |
2006-275 |
October 6, 2006 |
IRS Notice on Determination of Housing Cost Amount Excludible by U.S. Citizens Living Abroad |
2006-274 |
October 4, 2006 |
IRS Notice on Information Reporting for Payments of Interest on Tax-Exempt Bonds |
2006-273 |
October 4, 2006 |
IRS Delays Effective Date of Final Regulations Under Section 409A |
2006-272 |
October 2, 2006 |
Legislative Update: Tax Technical Corrections Bill Is Introduced by Ways and Means Chairman Thomas |
September 2006
Issue |
Date |
Subject |
2006-271 |
September 29, 2006 |
Additional Toyota, Lexus Vehicles Certified for Alternative Motor Vehicle Credit |
2006-270 |
September 29, 2006 |
IRS Updates Rev. Proc. 2005-67 Concerning Employee Lodging, Meals, and Incidental Expenses |
2006-269 |
September 29, 2006 |
IRS Guidance on Alternative Fuel and Alternative Fuel Mixtures |
2006-268 |
September 29, 2006 |
Legislative Update: Finance Chairman Says No Action on Extenders Prior to Election |
2006-267 |
September 29, 2006 |
United States, Iceland Conclude Income Tax Treaty Negotiations |
2006-266 |
September 27, 2006 |
IRS Reminds Taxpayers Affected by Hurricane Katrina of October 16th Filing Date |
2006-265 |
September 27, 2006 |
Legislative Update: Ways and Means Committee Approves HSA Bill |
2006-264 |
September 26, 2006 |
Eleventh Circuit: Taxpayer’s Dissolution Affected Legal Capacity to File Tax Court Petition |
2006-263 |
September 26, 2006 |
IRS Issues Interim Guidance on Section 45 Tax Credit for Electricity Produced from Open-Loop Biomass |
2006-262 |
September 25, 2006 |
IRS Practice & Procedure Alert: First-Time Schedule M-3 Filers Have 30 Days to Report Information to Their Partnerships |
2006-261 |
September 22, 2006 |
Regulations to Be Issued Under Section 367(b) to Address Certain Triangular Reorganizations Under Section 368(a) Involving Foreign Corporations |
2006-260 |
September 20, 2006 |
IRS Releases Phase-Out Schedule for Alternative Motor Vehicle Credit for Qualifying Toyota Vehicles |
2006-259 |
September 20, 2006 |
IRS Notice Provides a Tie-Breaking Rule for Two or More Taxpayers Claiming a Child as a Qualifying Child |
2006-258 |
September 19, 2006 |
Tax Court: Transportation Provided by Taxpayers Does Not Qualify for Section 34 Credit for Gasoline Taxes |
2006-257 |
September 19, 2006 |
Legislative Update: Senate Finance Committee to Take Testimony on Business Taxation in the United States |
2006-256 |
September 18, 2006 |
Legislative Update: Senate Finance Committee Releases Statutory Language, Description of Telephone Excise Tax Repeal Bill (Approved in June 2006) |
2006-255 |
September 15, 2006 |
Proposed Regulations Would Eliminate Country-by-Country Reporting to Shareholders of Foreign Taxes Paid by RICs |
2006-254 |
September 14, 2006 |
IRS Provides Procedures for Airlines and Airline Catering Services to Elect Alternative Funding Schedule |
2006-253 |
September 13, 2006 |
Reminder for Certain Large Corporations: Increase in Estimated Tax Installment Due September 15, 2006 |
2006-252 |
September 8, 2006 |
IRS Provides Guidance on Transition Rule Election Under Section 355(b)(3)(C) |
2006-251 |
September 7, 2006 |
IRS Reminds Taxpayers to Check Mailing Addresses for Documents to be Delivered to Chief Counsel’s Office |
2006-250 |
September 7, 2006 |
Temporary and Proposed Regulations Concerning the Railroad Track Maintenance Credit |
2006-249 |
September 6, 2006 |
Proposed Regulations on Income and Currency Gain or Loss With Respect to a Section 987 Qualified Business Unit |
2006-248 |
September 5, 2006 |
Final Regulations Relating to the Collection of Tax Liabilities After Assessment |
2006-247 |
September 1, 2006 |
United States, Isle of Man Tax Information Exchange Agreement Enters Into Force |
2006-246 |
September 1, 2006 |
IRS Updates Guidance on Special Depreciation Allowance for Gulf Opportunity Zone Property |
2006-245 |
September 1, 2006 |
IRS Clarifies Instructions for Mailing, Delivery of Documents to Chief Counsel’s Office |
August 2006
Issue |
Date |
Subject |
2006-244 |
August 31, 2006 |
Text of Final Regulations Providing Guidance on the Nonaccrual Experience Method of Accounting |
2006-243 |
August 31, 2006 |
IRS Announces Standard Amounts for Individuals to Use to Claim Refunds of Federal Telephone Excise Tax |
2006-242 |
August 31, 2006 |
IRS Modifies Procedures for Changes in Method of Accounting Under the INDOPCO Regulations |
2006-241 |
August 29, 2006 |
Text of Final Regulations on Bonus Depreciation Deduction |
2006-240 |
August 29, 2006 |
Final Regulations Concerning Dividends Paid Deduction for Stock Held in ESOPs |
2006-239 |
August 29, 2006 |
IRS Provides Additional Examples Illustrating Whether Income Is Derived from or Effectively Connected to U.S. Territory |
2006-238 |
August 28, 2006 |
Proposed Section 959 and Section 961 Regulations Update and Clarify Rules Relating to Exclusion of Previously Taxed Earnings and Profits and Related Basis Adjustments |
2006-237 |
August 28, 2006 |
District of Columbia: Appeals Court Upholds D.C.’s Unincorporated Business Tax |
2006-236 |
August 25, 2006 |
IRS Grants Additional Postponement of Filing/Payment Deadline for Gulf Coast Businesses to October 16, 2006 |
2006-235 |
August 24, 2006 |
New User Fees Apply for Processing Form 8802, Application for United States Residency Certification |
2006-234 |
August 24, 2006 |
New IRS Publication Provides Summary of Tax Incentives, Benefits to Victims of Hurricanes Katrina, Rita and Wilma |
2006-233 |
August 23, 2006 |
United States, Germany Correct Typographical Errors in Protocol |
2006-232 |
August 23, 2006 |
Fifth Circuit Upholds Taxpayers’ Valuations of Family Limited Partnership; Tax Court’s Reviewed Opinion Is Reversed |
2006-231 |
August 23, 2006 |
Eighth Circuit Reverses Tax Court to Find Professional Employer Organization Was Not Liable for Deficiency Relating to Per Diem Payments Made to Truck Drivers |
2006-230 |
August 23, 2006 |
Proposed Regulations Clarify Bank’s S Corporation Status Does Not Affect the Applicability of the Code’s “Special Bank Rules” |
2006-229 |
August 22, 2006 |
California Supreme Court Addresses Tax Implications of Short-Term Security Redemptions, Stock Repurchase Agreements, and Research Credits |
2006-228 |
August 22, 2006 |
D.C. Circuit Concludes Code Section 104(a)(2) Is Unconstitutional as Applied to Awards for Non-Physical Personal Injury |
2006-227 |
August 22, 2006 |
IRS Offers Fast Track Settlement for Small Business/Self Employed Taxpayers to Expedite Resolution of Issues |
2006-226 |
August 21, 2006 |
Discussion of Proposed “Repair Regulations” on the Deduction and Capitalization of Expenditures Related to Tangible Property |
2006-225 |
August 18, 2006 |
Text of Proposed Regulations on Capitalization of Tangible Assets |
2006-224 |
August 17, 2006 |
President Bush Signs Pension Protection Act of 2006 |
2006-223 |
August 15, 2006 |
2006-2007 Priority Guidance Plan Released |
2006-222 |
August 15, 2006 |
Temporary and Proposed Regulations Concerning the Determination of Interest Expense Deduction of Foreign Corporations |
2006-221 |
August 14, 2006 |
IRS Rules Plan Reimbursements for Medical Expenses Are Not Excludable from Employees’ Income if Plan Fails Section 105(b) |
2006-220 |
August 10, 2006 |
IRS Provides New Temporary Change of Address for Certain Hand-Delivered Documents |
2006-219 |
August 9, 2006 |
Michigan: Effective Date for Repeal of Single Business Tax Is Accelerated to December 31, 2007 |
2006-218 |
August 9, 2006 |
IRS Announces Purchasers of Qualified GM Hybrid Vehicles Can Continue to Qualify for Alternative Motor Vehicle Credit |
2006-217 |
August 9, 2006 |
IRS Revises Temporary Procedures Relating to Expedited Ruling Requests for Reorganizations and Section 355 Distributions |
2006-216 |
August 9, 2006 |
Seventh Circuit Addresses Standard to Be Used Concerning Valuation of Interest Swaps |
2006-215 |
August 8, 2006 |
IRS Revises Forms 8898 and 8840 for Determining Whether Individuals Have a “Closer Connection” to the United States or a Foreign Country |
2006-214 |
August 8, 2006 |
Final Regulations Address Interaction Between Anti-Cutback Rules and Nonforfeitability Requirements Under Section 411 |
2006-213 |
August 7, 2006 |
Text of Final Regulations Under Section 367(b) Concerning Carryover of Tax Attributes |
2006-212 |
August 7, 2006 |
Seventh Circuit Reverses District Court and Finds Cash Balance Plan Does Not Violate ERISA Age Discrimination Prohibitions |
2006-211 |
August 7, 2006 |
Proposed Section 901 “Technical Taxpayer” Regulations |
2006-210 |
August 4, 2006 |
IRS Guidance on Special Depreciation Allowance for Gulf Opportunity Zone Property |
2006-209 |
August 4, 2006 |
Legislative Update: Senate Approves Pension Legislation Before August Recess, but Not the Estate Tax/Extenders Bill |
2006-208 |
August 4, 2006 |
Sixth Circuit: Taxpayer’s Status as Co-obligor on Loan Not Sufficient to Increase Basis in Debt or Stock of S Corporation |
2006-207 |
August 4, 2006 |
Proposed Regulations Intend to Clarify When Accounts or Notes Receivable Are “Acquired for Services Rendered” |
2006-206 |
August 4, 2006 |
Second Circuit Reverses District Court; Finds That Foreign Banks Were Not Bona Fide Equity Partners |
2006-205 |
August 3, 2006 |
Proposed Regulations on Determining Who Is Considered to Pay Foreign Tax for Purposes of Sections 901 and 903 |
July 2006
Issue |
Date |
Subject |
2006-204 |
July 31, 2006 |
Final, Temporary, and Proposed Regulations Concerning Residual Interests: Accounting for REMIC Net Income by Foreign Holders |
2006-203 |
July 31, 2006 |
Final, Temporary, and Proposed Regulations Concerning Widely Held Investment Trusts |
2006-202 |
July 28, 2006 |
Legislative Update: Summaries and Statutory Language of Pension Bill and Estate Tax/Extenders Bill |
2006-201 |
July 28, 2006 |
Legislative Update: House Reportedly to Separate Extenders, Pension Bill |
2006-200 |
July 28, 2006 |
IRS Announces Change to Effective Date for Anti-Inversion Regulations |
2006-199 |
July 28, 2006 |
Final Regulations Concerning Employer Comparable Contributions to Health Savings Accounts |
2006-198 |
July 28, 2006 |
IRS Launches New Tip Reporting Program |
2006-197 |
July 25, 2006 |
Legislative Update: House to Consider Bill Barring States from Taxing Businesses with Limited In-State Activities and Those Not Physically Present in the State |
2006-196 |
July 25, 2006 |
Tax Court: Taxpayer Entitled to Amortize Favorable Financing Intangible Assets Because Reasonably Estimable Values and Ascertainable Remaining Useful Lives Were Established |
2006-195 |
July 24, 2006 |
Tax Court: IRA Distribution from Individual’s Own Account Is Subject to 10% Additional Tax Even Though Portion of Funds Was from Rollover of Deceased Husband’s IRA |
2006-194 |
July 24, 2006 |
Final Regulations on Withholding for Supplemental Wages |
2006-193 |
July 21, 2006 |
Text of Federal District Court’s Opinion Finding Retroactivity of Reg. Section 1.752 Is Invalid |
2006-192 |
July 20, 2006 |
IRS Announces Results of Quarterly Report of Honda Hybrid Vehicles Qualifying for the Alternative Motor Vehicle Tax Credit |
2006-191 |
July 20, 2006 |
Final Drafts of Schedules M-3 Are Released for 2006 |
2006-190 |
July 20, 2006 |
Proposed Regulations Relating to Third-Party and John Doe Summonses |
2006-189 |
July 19, 2006 |
Multistate Legislative Update: Reports from New Jersey, Pennsylvania, North Carolina, South Carolina, Tennessee, and Rhode Island |
2006-188 |
July 18, 2006 |
Legislative Update: House Approves Bill Barring State Taxation of Certain Retirement Income |
2006-187 |
July 14, 2006 |
Description of FASB Interpretation 48 Concerning Accounting for Income Tax Uncertainties |
2006-186 |
July 13, 2006 |
IRS Advises Employer-Provided Rebates or Cash Incentives to Employees for Hybrid Cars Are Taxable Compensation |
2006-185 |
July 13, 2006 |
Eleventh Circuit: Three-Year Limitations Period Applies to Refund Claims Even When Returns Were Mistakenly Filed and No Return Was Required |
2006-184 |
July 13, 2006 |
Interpretation of FASB Statement No. 109, Accounting for Uncertainty in Income Taxes |
2006-183 |
July 12, 2006 |
Federal Circuit Reverses Court of Federal Claims, and Finds Capital Loss Transaction Lacked Economic Substance |
2006-182 |
July 12, 2006 |
Proposed Regulations Concerning Exchange Rate Used for Determining Gain/Loss Under “DASTM” on Transfer of Assets from Qualified Business Unit to U.S. Home Office or Parent Corporation |
2006-181 |
July 12, 2006 |
Final Regulations on Reporting of Gross Proceeds Payments to Attorneys |
2006-180 |
July 11, 2006 |
IRS Certifies Model Years 2006 and 2007 GM Vehicles for Alternative Motor Vehicle Credit; Honda Vehicles Certified to Operate on Compressed Natural Gas |
2006-179 |
July 11, 2006 |
IRS Guidance on Use of Debit, Credit, and Stored-Value Cards in Self-Insured Medical Reimbursement Plans and Dependent Care Assistance Programs |
2006-178 |
July 11, 2006 |
IRS National Office Building Expected to Be Closed for Months |
2006-177 |
July 11, 2006 |
Kentucky: Further Changes to the Tax Modernization Act of 2005 |
2006-176 |
July 10, 2006 |
IRS Provides Temporary Procedures for Requests for Expedited Letter Rulings for Reorganizations and Section 355 Distributions |
2006-175 |
July 6, 2006 |
IRS Updates e-Filing Requirements for Large Corporations |
2006-174 |
July 5, 2006 |
Final Regulations Governing Section 338(h)(10) Elections and Multi-Step Transactions |
2006-173 |
July 5, 2006 |
IRS Provides Temporary Change of Address for Certain Hand-Delivered Documents While IRS National Office Remains Closed |
June 2006
Issue |
Date |
Subject |
2006-172 |
June 29, 2006 |
IRS National Office Remains Closed Due to Water Damage; No Date Set for Reopening |
2006-171 |
June 28, 2006 |
Legislative Update: Senate Finance Committee Approves Bill Repealing Telephone Excise Tax, Internet Tax Moratorium Sunset; Update on “Trailer Bill” and Estate Tax Bill |
2006-170 |
June 28, 2006 |
Court of Federal Claims Issues Supplementary Decision Concerning Layoff Payments Subject to FICA Requirements |
2006-169 |
June 28, 2006 |
Court of Federal Claims: Taxpayer’s Refund Claim Not Timely Filed Because the Loss Carryover Was Not Caused by a Loss Carryback |
2006-168 |
June 27, 2006 |
Legislative Update: Tax Committees to Consider Health Savings Accounts and Repeal of Federal Excise Tax on Telephone Services |
2006-167 |
June 23, 2006 |
Final Regulations Concerning Ownership Change of Loss Corporation on Distribution by Section 401(a) Trust to Plan Participants |
2006-166 |
June 22, 2006 |
Legislative Update: House Passes Estate Tax Reduction Bill |
2006-165 |
June 21, 2006 |
Ninth Circuit: Advance Trade Discounts Received by Grocery Retailers From Wholesalers Are Not Gross Income When Received |
2006-164 |
June 21, 2006 |
IRS Certifies Model Year 2007 Ford and Mercury Vehicles for Alternative Motor Vehicle Credit |
2006-163 |
June 20, 2006 |
Legislative Update: Description, Revenue Estimate of Estate Tax Relief Act of 2006 |
2006-162 |
June 20, 2006 |
Temporary Relief for Certain REITs and REIT Subsidiaries that Provide Accommodations to Persons Affected by Hurricanes Katrina and Rita |
2006-161 |
June 20, 2006 |
Final, Temporary and Proposed Regulations Issued Concerning Information Returns on Form 5471, With Respect to Certain Foreign Corporations Under Section 6038, and on Form 5472, With Respect to Certain Foreign-Owned Domestic Corporations Under Section 6038A |
2006-160 |
June 19, 2006 |
IRS Provides Safe Harbor Methods for Claiming Casualty and Theft Losses for Taxpayers Affected by Hurricanes Katrina, Rita, and Wilma |
2006-159 |
June 19, 2006 |
IRS Further Postpones Deadlines to October 16, 2006, for Taxpayers Affected by Hurricane Katrina to File Individual Returns |
2006-158 |
June 19, 2006 |
Guidance on Leave-Sharing Plans to Assist Employees Affected by a Major Disaster |
2006-157 |
June 16, 2006 |
IRS Postpones Due Date for Filing 8898, Statement for Individuals Beginning or Ending Residence in U.S. Possessions |
2006-156 |
June 16, 2006 |
Final FICA Regulations Concerning Payments Made to Domestic Service Workers, Agricultural Laborers, and Other Home Workers |
2006-155 |
June 14, 2006 |
Research Tax Credit: Proposed Legislation… New Opportunities! |
2006-154 |
June 13, 2006 |
Legislative Update: Senate Finance Committee Hearing Addresses Corporate Tax Issues |
2006-153 |
June 12, 2006 |
Proposed Regulations Under Sections 871 and 881 Relating to Exclusion of Portfolio Interest Paid to Nonresident Alien Individual or Foreign Corporation |
2006-152 |
June 8, 2006 |
IRS Seeks Recommendations for Reducing Taxpayer Burden |
2006-151 |
June 8, 2006 |
Legislative Update: Senate Efforts to Repeal Estate Tax Fail on Procedural Vote |
2006-150 |
June 7, 2006 |
IRS Issues Quarterly Report of Qualified Ford, Toyota Hybrid Vehicles for Alternative Motor Vehicle Credit |
2006-149 |
June 5, 2006 |
Additional Temporary and Proposed Regulations Issued Concerning Application of Section 7874 to Expatriated Entities and Surrogate Foreign Corporations |
2006-148 |
June 2, 2006 |
IRS Clarifies Earlier Guidance on Investments by Mutual Funds in Commodity-Index Contracts |
2006-147 |
June 2, 2006 |
IRS Issues Interim Guidance Relating to Qualified Alternative Motor Vehicle Credit |
2006-146 |
June 2, 2006 |
IRS Clarifies Earlier Guidance Concerning Energy Credits for Homeowners |
2006-145 |
June 2, 2006 |
IRS Interim Guidance for Commercial Property Owners to Qualify for Energy Efficiency Commercial Building Deduction |
2006-144 |
June 2, 2006 |
United States, Germany Sign Protocol to Income Tax Treaty |
2006-143 |
June 1, 2006 |
IRS Certifies Honda Vehicles Satisfy Criteria for Alternative Motor Vehicle Credit |
2006-142 |
June 1, 2006 |
Proposed Regulations Under Section 1248 Address Determinations of Earnings and Profits of CFCs After Certain Nonrecognition Transactions |
May 2006
Issue |
Date |
Subject |
2006-141 |
May 31, 2006 |
United States, Finland Sign Protocol to Income Tax Treaty |
2006-140 |
May 31, 2006 |
New IRS Process Would Expand Options for Direct Deposits of Tax Refunds |
2006-139 |
May 31, 2006 |
Legislative Update: Combat Zone Compensation Can Be Considered for Retirement Plan Purposes |
2006-138 |
May 26, 2006 |
Treasury, IRS Guidance Intended to Reduce e-Filing Burden for Corporations and Shareholders |
2006-137 |
May 25, 2006 |
Qualified Non-Mortgage Widely Held Fixed Investment Trusts Exception Is Extended |
2006-136 |
May 25, 2006 |
IRS Issues Guidance on Taxpayer Requests for Credit or Refund of Excise Tax on Long-Distance Telephone Services |
2006-135 |
May 25, 2006 |
Treasury Announces End to Long-Distance Telephone Excise Tax Dispute |
2006-134 |
May 24, 2006 |
Court of Federal Claims Finds “Untimely” Refund Claim Was a Proper Amendment to a Timely Filed Informal Refund Claim |
2006-133 |
May 24, 2006 |
Final Regulations on Domestic Production Activities Deduction Under Section 199 Are Released; Temporary and Proposed Regulations Address Deduction for Certain Transactions Involving Computer Software |
2006-132 |
May 23, 2006 |
Section 897 Final Regulations to Revise Rules Regarding Inbound and Foreign-to-Foreign Asset Reorganizations Involving Transfer of U.S. Real Property Interests |
2006-131 |
May 19, 2006 |
Texas: Tax Reform Legislation Is Enacted |
2006-130 |
May 17, 2006 |
President Bush Signs the Tax Increase Prevention and Reconciliation Act of 2005 |
2006-129 |
May 16, 2006 |
U.S. Tax Court Holds S Corporation Shareholders Must Recognize Section 481 Adjustment to Correct Errors in Valuing S Corporation’s Inventory |
2006-128 |
May 16, 2006 |
Analysis: U.S. Supreme Court Dismisses Sixth Circuit Court of Appeals Decision in DaimlerChrysler v. Cuno For Lack of Standing |
2006-127 |
May 16, 2006 |
EU Withdraws FSC/ETI Tariffs in Response to Repeal of Binding Contract Rule in the Tax Increase Prevention and Reconciliation Act of 2005 |
2006-126 |
May 15, 2006 |
U.S. Supreme Court Finds that Plaintiffs Lack Standing in DaimlerChrysler v. Cuno |
2006-125 |
May 11, 2006 |
Tax Court: Petitioner Entitled to Time Extension for Mark-to-Market Election Under 9100 Relief Provisions |
2006-124 |
May 11, 2006 |
Legislative Update: Tax Increase Prevention and Reconciliation Act of 2005 |
2006-123 |
May 9, 2006 |
Legislative Update: Agreement Reached on Tax Increase Prevention and Reconciliation Act of 2005 |
2006-122 |
May 9, 2006 |
Third Circuit Joins Second, Sixth, Eleventh, and D.C. Circuits in Holding Long-Distance Telephone Service Not Subject to Federal Communications Excise Tax |
2006-121 |
May 8, 2006 |
Tax Court: Coal Mines and Supply Contracts Are “Like-Kind” Property to Gold Mining Property Transferred |
2006-120 |
May 8, 2006 |
Ninth Circuit Finds Method Used to Reduce Pension Benefits Violated ERISA |
2006-119 |
May 5, 2006 |
IRS Updates Voluntary Correction Program for Retirement Plan Sponsors |
2006-118 |
May 5, 2006 |
Example Illustrating Treatment of Manufacturer Incentive Payments Between Members of a Consolidated Group Is Withdrawn |
2006-117 |
May 4, 2006 |
IRS User Fee for Requests Submitted to U.S. Competent Authority for Discretionary LOB Determinations |
2006-116 |
May 4, 2006 |
Revenue Ruling on Status of Surviving Spouse’s Interest When Marital Trust Is Beneficiary of Decedent’s IRA or Retirement Plan |
2006-115 |
May 3, 2006 |
United States and Denmark Sign Protocol to Income Tax Treaty |
2006-114 |
May 2, 2006 |
IRS Provides Interim Guidance Concerning Foreign Base Company Shipping Rules, and Changes to Subpart F Treatment of Aircraft and Vessel Leasing Income |
2006-113 |
May 1, 2006 |
Tax Court Addresses Interest Rate That Applies on Tax Overpayment by S Corporation |
2006-112 |
May 1, 2006 |
Revenue Procedure Updates Competent Authority Guidance for Tax Coordination Agreements Involving U.S. Possessions |
2006-111 |
May 1, 2006 |
IRS Guidance on Elections Created by the American Jobs Creation Act of 2004 |
2006-110 |
May 1, 2006 |
Legislative Update: Senate Leaders Agree to Withdraw LIFO-Repeal Proposal |
April 2006
Issue |
Date |
Subject |
2006-109 |
April 28, 2006 |
Legislative Update: Amendment to Supplemental Appropriations Bill Would Repeal LIFO Method of Accounting |
2006-108 |
April 28, 2006 |
IRS Releases Updated Draft Instructions for Schedule M-3 for Tax Year 2006 |
2006-107 |
April 26, 2006 |
U.S. Supreme Court: State Must Take Additional Reasonable Steps to Provide Notice of Tax Sale to Property’s Owner When Notice Is Returned Unclaimed |
2006-106 |
April 25, 2006 |
Tax Court: AMT Capital Loss from Exercise of Incentive Stock Options Cannot Be Carried Back to Reduce AMT Income |
2006-105 |
April 25, 2006 |
IRS Certifies Two Additional Vehicles for the New Energy Tax Credit |
2006-104 |
April 25, 2006 |
Puerto Rico: Competent Authority Procedures Concerning U.S. Federal Tax Determinations |
2006-103 |
April 24, 2006 |
Discussion of Temporary, Proposed Regulations on Foreign Tax Credit Treatment of Dividends From Noncontrolled 10/50 Corporations and Related Issues |
2006-102 |
April 24, 2006 |
IRS Provides Sample Amendment for Roth Elective Deferrals |
2006-101 |
April 24, 2006 |
Transitional Relief Under Final Regulations Concerning Statutory Mergers and Consolidations |
2006-100 |
April 24, 2006 |
Temporary, Proposed Regulations Address When to Include Insurance Companies in Life-Nonlife Consolidated Return |
2006-99 |
April 21, 2006 |
Text of Temporary, Proposed Regulations on Application of Separate Foreign Tax Credit Limitations to Dividends Received from Noncontrolled 10/50 Corporations |
2006-98 |
April 20, 2006 |
Tax Court: Closing Agreement on Form 906, Addressing Specific Matters Only, Requires IRS to Issue Deficiency Notice Before Making an Assessment |
2006-97 |
April 20, 2006 |
Federal Circuit: Taxpayer’s Interest Netting Claim Denied Because It Was Not Timely Filed |
2006-96 |
April 19, 2006 |
Tax Court: Taxpayer’s Case Dismissed Due to Corporate Status Being Suspended by the State in Which It Was Incorporated |
2006-95 |
April 19, 2006 |
IRS Extends Placed-in-Service Date for Bonus Depreciation in Areas Affected by Hurricanes Katrina, Rita, and Wilma |
2006-94 |
April 18, 2006 |
Withdrawal of Proposed Regulations Relating to “Basis-Shifting Transactions” |
2006-93 |
April 18, 2006 |
IRS Announces New Form 8898 for Individuals Beginning or Ending Residence in U.S. Possessions |
2006-92 |
April 17, 2006 |
IRS Guidance on Credit for Production from Advanced Nuclear Facilities |
2006-91 |
April 17, 2006 |
IRS Adds Catastrophic Event to Waiver Guidance for Corporations Unable to Comply with Electronic Return Filing Requirements |
2006-90 |
April 14, 2006 |
Sixth Circuit Finds Shareholder Advances Were Legitimate Loans, and Allows Interest Deductions; Tax Court Is Reversed |
2006-89 |
April 7, 2006 |
IRS Releases List of Vehicles That Qualify for the New Energy Tax Credit |
2006-88 |
April 7, 2006 |
Final and Temporary Regulations Under Sections 338 and 1060 Apply to Deemed Sale or Acquisition of Insurance Company’s Assets |
2006-87 |
April 7, 2006 |
Partnerships Withholding on Foreign Partners Under Final Section 1446 Regulations to Attach Computation of Income at Preferential Rates to Form 8804 for Affected Year |
2006-86 |
April 5, 2006 |
IRS Releases Draft Schedules M-3 for 2006 |
2006-85 |
April 3, 2006 |
Legislative Update: Senate Approves Protocols to Tax Treaties with France, Sweden and Tax Treaty with Bangladesh |
March 2006
Issue |
Date |
Subject |
2006-84 |
March 28, 2006 |
Kentucky: New Law, Regulations Clarify and Supplement Items Under the Tax Modernization Act of 2005 |
2006-83 |
March 27, 2006 |
Indiana: New Related-Party Expense Disallowance, Phase-in of Single Factor Apportionment Measures Are Enacted |
2006-82 |
March 24, 2006 |
Treasury, IRS Invite Comments, Recommendations for Items to Be Included in 2006-2007 Guidance Priority List |
2006-81 |
March 23, 2006 |
IRS Notice Affords Additional Relief to Taxpayers with Rehabilitation Credit Property Located in Areas Affected by Hurricanes in 2005 |
2006-80 |
March 23, 2006 |
Final Regulations Revise Rules Concerning Disclosure of Relative Values of Optional Forms of Benefit |
2006-79 |
March 22, 2006 |
Treasury Regulations Could Reduce Foreign Corporations’ Filings of Treaty-Based Return Position Disclosures Under Section 6114: Effective for Tax Years Ending After 2004 |
2006-78 |
March 21, 2006 |
IRS Notice Provides Transition Relief for Plans to Satisfy Section 409A(b) Requirements |
2006-77 |
March 20, 2006 |
IRS Announces Luxury Automobile Depreciation Deduction Limitations for 2006 |
2006-76 |
March 20, 2006 |
Legislative Update: JCT Side-by-Side Comparison of Revenue Effects of Pension Bills |
2006-75 |
March 17, 2006 |
Reminder: Rules Adopting a Reasonable Cause Standard for Dual Consolidated Loss Filings Are Effective March 23, 2006 |
2006-74 |
March 17, 2006 |
IRS Notice: Branch of Financial Institution Cannot Be Qualified Intermediary After 2006 Unless in a Country With “Know-Your-Customer” Rules |
2006-73 |
March 17, 2006 |
Reminder: Oil Spill Excise Tax Reinstated as of April 1, 2006 |
2006-72 |
March 15, 2006 |
IRS Requests Comments on Cross License Transactions |
2006-71 |
March 15, 2006 |
Legislative Update: WTO Dispute Settlement Body Adopts Appellate Body and Panel Findings That American Jobs Creation Act of 2004 Continues to Provide Prohibited Subsidies |
2006-70 |
March 15, 2006 |
Legislative Update: Senator Introduces Bill to Require Basis Reporting |
2006-69 |
March 14, 2006 |
Court of Federal Claims: Recognition of Income Relating to Stock Options Using Margin Loans |
2006-68 |
March 14, 2006 |
Legislative Update: Senate Foreign Relations Committee Approves Protocols to Tax Treaties with France, Sweden and Tax Treaty with Bangladesh |
2006-67 |
March 13, 2006 |
Tax Court: Taxpayer’s Use of Incremental Cost Allocation Method Found to Be Reasonable Allocation Method |
2006-66 |
March 13, 2006 |
Legislative Update: JCT Analysis of Tax Proposals in President’s FY 2007 Budget |
2006-65 |
March 13, 2006 |
Final Regulations: Withholding Tax on Certain U.S. Source Payments Made to Foreign Persons and Information Reporting Requirements |
2006-64 |
March 13, 2006 |
California: Limited Liability Company (LLC) Fee Held Unconstitutional |
2006-63 |
March 9, 2006 |
Regulations Allow IRS to Designate Domestic Member of Consolidated Group as Substitute Agent When Group Has Foreign Common Parent |
2006-62 |
March 9, 2006 |
Final Regulations Under Section 1502 Concerning the Suspension of Losses on Certain Stock Dispositions |
2006-61 |
March 8, 2006 |
Legislative Update: Side-by-Side Comparison of Provisions in House, Senate Pension Bills |
2006-60 |
March 8, 2006 |
IRS Updates Waiver Guidance for Corporations Unable to Comply with Electronic Return Filing Requirements; New Provisions Concern Substitute Return Process for Carrying Back NOLs |
2006-59 |
March 6, 2006 |
First Periodic Update of the 2005-2006 Priority Guidance Plan |
February 2006
Issue |
Date |
Subject |
2006-58 |
February 23, 2006 |
IRS Amends Rules Concerning Reporting Requirements for Non-Mortgage Widely Held Fixed Investment Trusts |
2006-57 |
February 21, 2006 |
IRS Guidance on Coal Project Credit and Gasification Project Credit, and on Energy Credits for Homeowners and for Home Builders |
2006-56 |
February 21, 2006 |
Final Regulations Provide Special Pro Rata Allocation Rules for Subpart F Income |
2006-55 |
February 20, 2006 |
IRS Further Postpones Deadlines to August 28, 2006, for Taxpayers Affected by Hurricane Katrina to File Returns, Documents and Pay Taxes |
2006-54 |
February 17, 2006 |
Final Regulations Address Application of Section 367 to Cross-Border Stock Transfers to Which Section 304 Applies |
2006-53 |
February 16, 2006 |
IRS Reminds Business Taxpayers of Streamlined Process for Extensions of Time to File Returns |
2006-52 |
February 15, 2006 |
IRS Releases Notice Allowing Taxpayers Affected by Hurricanes More Time to Claim Losses on Prior Year Returns |
2006-51 |
February 15, 2006 |
New Jersey: Regulation Prohibits Dividends Received Deduction for REIT Distributions |
2006-50 |
February 14, 2006 |
Third Circuit: Lump-Sum Consideration Paid for Right to Lottery Payments Is Ordinary Income |
2006-49 |
February 14, 2006 |
IRS Clarifies Which Transactions Are Not the Same as or Substantially Similar to “Listed Transactions” in Notice 2002-35 |
2006-48 |
February 13, 2006 |
Legislative Update: WTO Appellate Body Finds American Jobs Creation Act of 2004 Continues to Provide Prohibited Subsidies |
2006-47 |
February 13, 2006 |
Seventh Circuit Affirms Tax Court’s Finding That Reg. Section 1.267(a)-3, Concerning Payments to Foreign Related Persons, Is Valid |
2006-46 |
February 8, 2006 |
Sixth Circuit Affirms Tax Court’s Judgment Concerning Accrual of Warranty Expenses, Limitations Period for FTC Elections, and ESOP Redemption-Related Expenses |
2006-45 |
February 8, 2006 |
IRS Adds Model Year 2006 Toyota Prius Hybrid to List of Vehicles Eligible for Clean-Burning Fuel Deduction |
2006-44 |
February 8, 2006 |
Kentucky: Corporate Partner Was Not Subject to Kentucky Corporate Income Tax |
2006-43 |
February 6, 2006 |
IRS Rules Section 45 Credit for Electricity Produced from Qualified Energy Resource Is Not Reduced by State and Local Tax Credit |
2006-42 |
February 6, 2006 |
Second Circuit: NOL Carried Back to Pre-AMT Years Must Be Offset by Regular Taxable Income, Not Hypothetical AMT |
2006-41 |
February 6, 2006 |
Legislative Update: President Bush Proposes $1.7 Trillion in Tax Cuts |
2006-40 |
February 3, 2006 |
Regulations Concerning Taxation of Income Earned on Qualified Settlement Funds and Escrow Accounts |
2006-39 |
February 3, 2006 |
IRS Extends the Safe Harbor for Charitable Remainder Annuity Trusts Regarding State-Law Elections of Surviving Spouses |
2006-38 |
February 3, 2006 |
Legislative Update: Senate Passes Tax Bill to Clear Way for Conference |
2006-37 |
February 2, 2006 |
Fourth Circuit: Summary Judgment Not Appropriate Concerning Sham Transaction Doctrine; Validity of Claimed Loss Turns on Issues of Material Fact |
2006-36 |
February 2, 2006 |
IRS and Treasury Request Comments on Alternatives to Simplify the Section 751(b) Regulations |
2006-35 |
February 1, 2006 |
IRS Temporarily Suspends Certain Low-Income Housing Credit Requirements Due to Hurricane Rita |
2006-34 |
February 1, 2006 |
IRS Guidance on Retroactive Allocation of Commercial Revitalization Expenditure Amounts for Qualified Buildings in Expanded Community Renewal Areas |
January 2006
Issue |
Date |
Subject |
2006-33 |
January 31, 2006 |
Legislative Update: Tax Reconciliation, Pension Reform on Agenda as Congress Reconvenes |
2006-32 |
January 31, 2006 |
IRS Announces Future Rules Adopting a Reasonable Cause Standard for Dual Consolidated Loss Filings |
2006-31 |
January 30, 2006 |
IRS Relief from Certain Backup Withholding Obligations With Respect to Hurricane Victims |
2006-30 |
January 30, 2006 |
Final Regulations Provide Guidance Concerning Residency of Taxpayers in U.S. Possessions |
2006-29 |
January 27, 2006 |
Update on Ratification Process in the United States of Protocols to Tax Treaties with France and Sweden, and of Tax Treaty with Bangladesh |
2006-28 |
January 27, 2006 |
Final Regulations Defining “Corporation” and “Domestic” for Purposes of Entities Created or Organized in More Than One Jurisdiction |
2006-27 |
January 27, 2006 |
Final Regulations Providing Alternative Method for Determining Tax Book Value of Assets for Allocation and Apportionment of Expenses That May Increase Foreign Tax Credit Limitation |
2006-26 |
January 26, 2006 |
Tax Court Holds Timely Filing Requirement in Treasury Regulations Under Section 882 Is Invalid |
2006-25 |
January 25, 2006 |
Tax Court Finds Antarctica Is Not a Foreign Country for Section 911 Purposes |
2006-24 |
January 25, 2006 |
Proposed Rules Relating to Designated Roth Accounts |
2006-23 |
January 24, 2006 |
Discussion of Final Regulations for Determining Basis of Stock or Securities Received in Certain Reorganization Transactions |
2006-22 |
January 23, 2006 |
Final Regulations Defining “Statutory Merger or Consolidation” |
2006-21 |
January 23, 2006 |
Final Regulations for Determining Basis of Stock or Securities Received in Certain Reorganization Transactions |
2006-20 |
January 23, 2006 |
Sixth Circuit Reverses District Court, Finds COLI Plans Were “Economic Shams” |
2006-19 |
January 23, 2006 |
Final Regulations Clarify Rules for Widely Held Fixed Investment Trusts |
2006-18 |
January 19, 2006 |
IRS Provides Summary Discussion of Tax Incentives for Individual Taxpayers Under the Energy Policy Act of 2005 |
2006-17 |
January 19, 2006 |
IRS Further Clarifies Schedule D Instructions for 2005, Including Guidance for Individual Taxpayers Who File Electronic Returns |
2006-16 |
January 17, 2006 |
Tax Court: Lower Rate of Interest (Under GATT) Applies to Corporate Taxpayer’s Overpayment as of December 31, 1994 |
2006-15 |
January 13, 2006 |
Final and Temporary Regulations Modify Active Income Exception for Insurance CFCs with Interests in a Partnership |
2006-14 |
January 13, 2006 |
IRS Releases Interim Guidance with Procedures for Vehicle Manufacturers to Follow in Certifying Vehicles for New Lean Burn Technology and Qualified Hybrid Credits |
2006-13 |
January 12, 2006 |
IRS Fact Sheet Offers Overview of Recent Tax Law Changes Affecting Businesses and Employers in the Gulf Region |
2006-12 |
January 12, 2006 |
IRS Revises Form 1041 Schedule K-1 for Use by Trusts |
2006-11 |
January 12, 2006 |
UPDATE: Application of U.S. Inversion Rules to Joint Venture Structures |
2006-10 |
January 10, 2006 |
IRS Clarifies Changes to Form 1040 Schedule D Instructions for 2005 |
2006-09 |
January 10, 2006 |
IRS Outlines Tax Law Changes Related to Hurricanes Katrina, Rita, and Wilma |
2006-08 |
January 10, 2006 |
IRS Provides Penalty Relief for Payments of Loan Origination Fees and Capitalized Interest Relating to Qualified Education Loans |
2006-07 |
January 9, 2006 |
State Courts in New Mexico, Oklahoma Uphold Income Tax on Out-of-State Companies Licensing Intangibles for Use in Those States |
2006-06 |
January 9, 2006 |
Changes to Form 1040 Schedule D Instructions for 2005 |
2006-05 |
January 6, 2006 |
Court of Federal Claims Addresses Taxation of Branch Income Under United States-United Kingdom Income Tax Treaty |
2006-04 |
January 6, 2006 |
IRS Changes Reporting for Certain Transactions with Significant Book-Tax Differences |
2006-03 |
January 6, 2006 |
Eighth Circuit Affirms Tax Court’s Finding of Gift Tax Deficiencies in Family Limited Partnership Transfers |
2006-02 |
January 4, 2006 |
IRS Provides Safe Harbor Method of Accounting for Heavy Equipment Parts Inventory of Heavy Equipment Dealers |
2006-01 |
January 3, 2006 |
IRS Announces Launch of 2006 Filing Season |
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