Bulletin No. 2006-2 January 9, 2006

excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC.

T.D. 9232, page 266. REG–133446–03, page 299. Temporary and proposed regulations under section 1297 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC. A public hearing on the proposed regulations is scheduled for March 22, 2006.

Notice 2006–2, page 278. Extension of transition relief for certain partnerships and other pass-thru entities under section 470. This notice extends the transition relief under section 470 of the Code provided under Notice 2005–29, 2005–13 I.R.B. 796, to partnerships and certain other pass-thru entities that are treated as holding tax-exempt use property because of the application of section 168(h)(6), to taxable years that begin before January 1, 2006. Notice 2005–29 modified and superseded.

Rev. Proc. 2006–9, page 278. This procedure explains the manner in which taxpayers may request an advance pricing agreement (APA) from the APA Program within the Office of the Associate Chief Counsel (International), the manner in which such a request will be processed by the APA Program, and the effect and administration of APAs. Rev. Proc. 2004–40 superseded.

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Rev. Proc. 2006–10, page 293. This procedure supersedes Rev. Proc. 96–52, 1996–2 C.B. 372. It describes the qualifications necessary to become an acceptance agent and the procedures that an acceptance agent applicant must follow for purposes of entering into an acceptance agent agreement with the IRS. Rev. Proc. 96–52 superseded.

Announcement 2006–2, page 300. The December 2005 revision of Form 8609, Low-Income Hous- ing Credit Allocation and Certification, contains changes from the previous revision. Form 8609–A, Annual Statement for Low-Income Housing Credit, is replacing Schedule A (Form 8609).