Temporary and proposed regulations under section 6103 of the Code provide additional items of return information disclosable to the Bureau of Economic Analysis of the Department of Commerce.

Temporary and proposed regulations under section 6103 of the Code provide additional items of return information disclosable to the Bureau of Economic Analysis of the Department of Commerce.

Final, temporary, and proposed regulations deal with transfer prices in particular categories of transactions between related parties within the meaning of section 482 of the Code. They provide guidance regarding services transactions by updating regulations under section 482 issued in 1968. The regulations address determination of ownership of intangible property among related parties under section 482 and allocations with respect to “contributions” to the value of intangible property by a related party other than the owner. They also modify the treatment of stewardship expenses under regulations section 1.861-8. The temporary regulations are effective for tax years beginning after December 31, 2006.

Final, temporary, and proposed regulations deal with transfer prices in particular categories of transactions between related parties within the meaning of section 482 of the Code. They provide guidance regarding services transactions by updating regulations under section 482 issued in 1968. The regulations address determination of ownership of intangible property among related parties under section 482 and allocations with respect to “contributions” to the value of intangible property by a related party other than the owner. They also modify the treatment of stewardship expenses under regulations section 1.861-8. The temporary regulations are effective for tax years beginning after December 31, 2006.

This notice modifies Notice 2006-53, 2006-26 I.R.B. 1180, by extending the effective date of that publication from June 26, 2006, to December 1, 2006.

This announcement includes a proposed revenue procedure that identifies particular services that are eligible to be evaluated at cost according to the temporary regulations relating to services under section 482, which were released concurrently with this announcement. After receiving comments on the proposed revenue procedure, the Service intends to finalize the revenue procedure prior to December 31, 2006.