This is the table of contents of Internal Revenue Bulletin IRB 2012-27. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.
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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 July 2012.
Proposed regulations under section 1366 of the Code relate to basis of indebtedness of S corporations to their shareholders. The proposed regulations provide that S corporation shareholders increase their basis of indebtedness of the S corporation to the shareholder only if the indebtedness is bona fide. The proposed regulations affect shareholders of S corporations. A public hearing is scheduled for October 9, 2012.
This procedure provides a safe harbor for determining whether a publicly traded partnership’s (PTP’s) income from discharge of indebtedness (COD income) is qualifying income under section 7704(d) of the Code for the purpose of meeting the qualifying income exception in section 7704(c). The safe harbor treats COD income attributable to debt incurred in direct connection with the PTP’s activities that generate qualifying income (qualifying activities) as qualifying income.
This announcement withdraws (REG-100276-97) relating to financial asset securitization trusts (FASITs) under sections 860H through 860L of the Code. The FASIT provisions were repealed by PL 108-357, effective January 1, 2005, with limited exception for existing FASITs.
The following is a copy of the Competent Authority Agreement (“the Agreement”) entered into on May 21, 2012, by the Competent Authorities of the United States and the Netherlands regarding the eligibility of a besloten fonds voor gemene rekening (limited fund for mutual account) (“LFMA”) and its participants for treaty-reduced rates of withholding on U.S. source dividends and interest under the Convention between the Kingdom of the Netherlands and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed on December 18, 1992, and amended by Protocols signed on October 13, 1993 and March 8, 2004.
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