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INCOME TAX

Internal Revenue Bulletin 2006-2 · 2026-10-03 edition · updated 2026-10-04 · United States

Rev. Rul. 2006–1, page 261. Regulated investment company (RIC). A RIC’s income from a derivative contract with respect to a commodity index is not qualifying income for purposes of section 851(b)(2) of the Code if the income from the contract is not derived with respect to the RIC’s business of investing in stocks, securities, or currencies. Such a contract is not a security for purposes of section 851(b)(2).

Rev. Rul. 2006–2, page 261. Section 351. The conclusion in Rev. Rul. 74–503 that a transferor’s basis in transferee stock received in exchange for transferor stock is determined under section 362(a) of the Code is incorrect. The other conclusions in the ruling are under study. Rev. Rul. 74–503 revoked.

Rev. Rul. 2006–3, page 276. Japanese Yugen Kaisha (YK) and Tokurei Yugen Kaisha (TYK). A Yugen Kaisha, a Japanese business entity, which will become a Tokurei Yugen Kaisha under recently enacted Japanese legislation, will continue to be eligible to elect its U.S. entity classification under the check the box regulations.

Rev. Rul. 2006–4, page 264. 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 January 2006.

T.D. 9231, page 272. Final regulations under section 1298 of the Code provide guidance for making certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC)

Finding Lists begin on page ii.

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