Typically yes, although there might be some small delays (probably <2 weeks). Typically as soon as a new OS / iLife begin being sold, they are included in both refurbs and new computers.
The safest bet is to wait until the product pages change at the Apple Store. People have had luck with asking Apple for gratis upgrades when they buy after the announcement and before the store is changed, but technically this is a favor from Apple since the purchase was made based on the site that said iLife 06 or whatever....
Does that answer?