Internal Revenue Bulletin:  2012-11 

March 12, 2012 

INCOME TAX


Rev. Rul. 2012-9 Rev. Rul. 2012-9

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 March 2012.

T.D. 9569 T.D. 9569

Final, temporary, and proposed regulations under section 482 of the Code address concerns that taxpayers are taking unreasonable positions with respect to the determination of discount rates in applying the income method to determine taxable income in connection with cost sharing arrangements. The regulations provide guidance on a discount rate- related best method consideration for evaluating an application of the income method.

REG-145474-11 REG-145474-11

Final, temporary, and proposed regulations under section 482 of the Code address concerns that taxpayers are taking unreasonable positions with respect to the determination of discount rates in applying the income method to determine taxable income in connection with cost sharing arrangements. The regulations provide guidance on a discount rate- related best method consideration for evaluating an application of the income method.

T.D. 9571 T.D. 9571

Temporary and proposed regulations under section 904 of the Code provide transition rules regarding the reduction of the number of separate foreign tax credit limitation categories. A public hearing on the proposed regulations is scheduled for April 3, 2012.

REG-113903-10 REG-113903-10

Temporary and proposed regulations under section 904 of the Code provide transition rules regarding the reduction of the number of separate foreign tax credit limitation categories. A public hearing on the proposed regulations is scheduled for April 3, 2012.

T.D. 9572 T.D. 9572

Temporary and proposed regulations under section 871 of the Code provide a definition of the term “specified notional principal contract.” The temporary regulation also amend the provision of the Code to address the treatment of dividend equivalents. A public hearing on the proposed regulation is scheduled for April 27, 2012.

REG-120282-10 REG-120282-10

Temporary and proposed regulations under section 871 of the Code provide a definition of the term “specified notional principal contract.” The temporary regulation also amend the provision of the Code to address the treatment of dividend equivalents. A public hearing on the proposed regulation is scheduled for April 27, 2012.

Notice 2012-23 Notice 2012-23

This notice answers several questions about the federal income tax consequences related to the receipt of a section 1603 payment, a cash reimbursement from the Department of Treasury for a portion of the cost of certain qualifying renewable energy projects. The section 1603 program was created by the American Recovery and Reinvestment Tax Act of 2009 and was extended for one year by the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

Rev. Proc. 2012-21 Rev. Proc. 2012-21

This procedure provides guidance to individuals who fail to meet the eligibility requirements of section 911 of the Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries for tax year 2011 and the dates those countries are subject to the section 911(d)(4) waiver is provided.


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