HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Notice 2012–39, page 95. 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.

Notice 2012–48, page 102. 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.

Notice 2012–49, page 119. 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.

Finding Lists begin on page ii. Index for July begins on page iv.