INCOME TAX—Cont.

Marginal production rates, 2012 (Notice 50) 31, 121 Modification to consolidated return regulation permitting an

election to treat a liquidation of a target, followed by a recontribution to a new target, as a cross-chain reorganization (TD 9594) 29, 57 Overall foreign loss recapture on property dispositions (REG–134935–11) 29, 64 Proposed Regulations:

26 CFR 1.108–7, amended; 1.366–0, amended; 1.1366–2, –5, amended; 1.1367–1(h), amended; 1.1367–3, amended; basis of indebtedness of S corporations to their shareholders (REG–134042–07) 27, 5 26 CFR 1.904–4, amended; 1.904(g)–3, amended; overall foreign loss recapture on property dispositions (REG–134935–11) 29, 64 26 CFR 1.7874–3, added; substantial business activities (REG–107889–12) 28, 53 Qualifying income under section 7704(d) (RP 28) 27, 4 Regulations:

26 CFR 1.904–0, –1, –2, –7, –8, amended; 1.904(f)–0T, –1T, –2T, –7T, –8T, removed; 1.904(g)–0, –1, –2, –3, amended; 1.904(g)–0T, –1T, –2T, –3T, removed; 1.502–9, amended, 1.1502–9T, removed; treatment of overall foreign and domestic losses (TD 9595) 30, 71 26 CFR 1.1502–13, amended; 1.1502–13T, removed; 602.101, amended; modification to consolidated return regulation permitting an election to treat a liquidation of a target, followed by a recontribution to a new target, as a cross-chain reorganization (TD 9594) 29, 57 26 CFR 1.7874–1, amended; 1.7874–1T, removed; 1.7874–2, added; surrogate foreign corporations (TD 9591) 28, 32 26 CFR 1.7874–3T, added; substantial business activities (TD 9592) 28, 41 Section 43 inflation adjustment, 2012 (Notice 49) 31, 119 Substantial business activities (TD 9592) 28, 41 ; (REG–107889–12) 28, 53 Surrogate foreign corporations (TD 9591) 28, 32 Tax Convention:

U.S.-Netherlands agreement of limited funds for mutual ac count (LFMA) (Ann 26) 27, 8 Treatment of income from certain government bonds for pur poses of the passive foreign investment company (PFIC) rules (Notice 45) 29, 59 Treatment of overall foreign and domestic losses (TD 9595) 30,

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2012–31 I.R.B. v July 30, 2012

July 30, 2012 2012–31 I.R.B.

2012–31 I.R.B. July 30, 2012

July 30, 2012 2012–31 I.R.B.