INCOME TAX

Rev. Rul. 2012–19, page 16. 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, page 32. 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, page 41. REG–107889–12, page 53. 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, page 45. This notice provides guidance regarding certain qualified conservation purposes eligible for financing with qualified energy conservation bonds under section 54D of the Code, particu

Finding Lists begin on page ii.