TAX CONVENTIONS

Announcement 2006–21, page 703. This announcement sets forth a copy of the mutual agreement entered into on February 15, 2006, by the Competent Authorities of the United States and Spain, regarding the treatment of limited liability companies (LLCs), S corporations, and other business entities treated as partnerships or disregarded entities for U.S. tax purposes under the U.S.-Spain income tax treaty and protocol.