SECTION 3. NOTICE 2012–45

The Department of the Treasury and the Internal Revenue Service published Notice 2012–45, which provides that for certain taxable years and solely for purposes of section 1297, income from “Qualifying Government Bonds” held by an “Active Bank” qualifies for the active banking exception, as those terms are defined in the notice. Notice 2012–45 applies only to taxable years of foreign corporations beginning in 2011, 2012, and 2013.