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Internal Revenue Bulletin:  2012-40 

October 1, 2012 


T.D. 9599 T.D. 9599

Final regulations under section 1273 of the Code clarify the circumstances in which property is traded on an established market (that is, publicly traded) for purposes of determining the issue price of a debt instrument.

Rev. Proc. 2012-40 Rev. Proc. 2012-40

This procedure provides domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2010.

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