Internal Revenue Bulletin: 2012-31
July 30, 2012
This notice provides guidance under section 367(d) of the Code addressing transactions that raise significant policy concerns involving transfers of intangible property by a domestic corporation to a foreign corporation in certain corporate reorganizations.
This notice solicits applications for the allocation of available amounts of national bond issuance authority limitation (volume cap) for Tribal Economic Development Bonds under section 7871(f) of the Code. The notice provides guidance on: (1) the application requirements and forms for requests for volume cap allocations, (2) the general process that will be used by the IRS to allocate the volume cap, and (3) information reporting to the IRS concerning various aspects of the allocation process and the issuance of Tribal Economic Development Bonds pursuant to an allocation of volume cap.
2012 section 43 inflation adjustment. This notice announces the inflation adjustment factor and phase-out amount for the enhanced oil recovery credit for taxable years beginning in the 2012 calendar year. The format of the notice is identical to the format of previously published notices on this issue. The notice concludes that because the reference price for the 2011 calendar year ($95.73) exceeds $28 multiplied by the inflation adjustment factor for the 2011 calendar year ($43.92) by $51.81, the enhanced oil recovery credit for qualified costs paid or incurred in 2012 is phased out completely. The notice also contains the previously published figures for taxable years beginning in the 1991 through 2011 calendar years.
2012 marginal production rates. This notice announces that under section 613A(c)(6)(C) of the Code, the applicable percentage for purposes of determining percentage depletion on marginal properties for calendar year 2012 is 15 percent. The format of the notice is identical to the format of notices previously published on this issue.
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