Internal Revenue Bulletin:  2012-28 

July 9, 2012 

INCOME TAX


Rev. Rul. 2012-19 Rev. Rul. 2012-19

Dividends and dividend equivalents on restricted stock and restricted stock units. This ruling addresses whether dividends and dividend equivalents relating to restricted stock and restricted stock units that are performance-based compensation under section 162(m)(4)(C) of the Code must separately satisfy the requirements under section 162(m)(4)(C) to be treated as performance-based compensation.

T.D. 9591 T.D. 9591

Final regulations under section 7874 of the Code provide rules for determining whether a foreign corporation is a surrogate foreign corporation. Specifically, the regulation explains when there is an indirect acquisition of a domestic corporation’s properties for purposes of section 7874(a)(2)(B). In addition, the regulation includes a rule that in certain situations, a publicly traded partnership may be treated as a surrogate foreign corporation. The regulation also provides rules for the treatment of options of the surrogate foreign corporation for purposes of section 7874(a)(2)(B)(ii).

T.D. 9592 T.D. 9592

Temporary and proposed regulations under section 7874 of the Code provide guidance regarding whether a foreign corporation has substantial business activities in the foreign country in which, or under the law of which, the foreign corporation is created or organized.

REG-107889-12 REG-107889-12

Temporary and proposed regulations under section 7874 of the Code provide guidance regarding whether a foreign corporation has substantial business activities in the foreign country in which, or under the law of which, the foreign corporation is created or organized.

Notice 2012-44 Notice 2012-44

This notice provides guidance regarding certain qualified conservation purposes eligible for financing with qualified energy conservation bonds under section 54D of the Code, particularly (1) how to measure reductions of energy consumption in publicly-owned buildings by at least 20 percent, and (2) what constitutes a “green community program.”

Rev. Proc. 2012-29 Rev. Proc. 2012-29

This procedure provides sample language that may be used (but is not required to be used) for making an election under section 83(b) of the Code. Additionally, the procedure provides examples of the income tax consequences of making such an election.


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