Internal Revenue Bulletin 2012-20 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 201
2-20
May 14, 2012
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
T.D. 9584, page 900.
Final regulations under section 6049 of the Code provide guid-
ance regarding the reporting requirements for interest paid to
the U.S. accounts of certain nonresident alien individuals. The
reporting required by these final regulations will support the
U.S. government’s efforts to combat offshore tax evasion.
Notice 2012–31, page 906.
This notice describes and requests comments on several ap-
proaches for determining whether health coverage under an
eligible employer-sponsored plan provides minimum value for
purposes of sections 36B and 4980H of the Code.
Notice 2012–32, page 910.
This notice requests comments on information reporting under
section 6055 of the Code by health insurance issuers, govern-
ment agencies, employers that sponsor self-insured plans, and
other persons that provide minimum essential coverage to an
individual.
Notice 2012–33, page 912.
This notice invites comments on reporting under section 6056
of the Code by applicable large employers (as defined in section
4980H(c)(2)) that are subject to section 4980H. Section 6056
requires reporting of certain information on employer-provided
health care coverage provided on or after January 1, 2014.
The notice also advises the public that the Treasury and IRS
intend to propose regulations implementing section 6056 and
invites comments on issues arising under section 6056, includ-
ing on possible approaches for coordinating and minimizing du-
plication between the information required to be reported and
furnished by employers under section 6056 and information re-
quired to be reported and/or furnished by employers or other
persons under other applicable Code provisions.
Rev. Proc. 2012–24, page 913.
This procedure provides guidance for implementing final regu-
lations under section 6049 of the Code. The procedure con-
tains two lists of countries with which the IRS has an income
tax or other convention or bilateral agreement relating to the
exchange of information for tax administration purposes.
Rev. Proc. 2012–26, page 933.
This procedure provides the 2013 inflation adjusted amounts
for Health Savings Accounts (HSAs) under section 223 of the
Code.
EMPLOYEE PLANS
Notice 2012–31, page 906.
This notice describes and requests comments on several ap-
proaches for determining whether health coverage under an
eligible employer-sponsored plan provides minimum value for
purposes of sections 36B and 4980H of the Code.
EXEMPT ORGANIZATIONS
Announcement 2012–19, page 934.
This announcement makes it optional for Form 990 filers
for Tax Year 2011 to report their interests in the income,
expenses, and assets of partnerships using information from
Schedule K-1 of Form 1065, as opposed to using their books
and records.
(Continued on the next page)
Finding Lists begin on page ii.

ADMINISTRATIVE
T.D. 9584, page 900.
Final regulations under section 6049 of the Code provide guid-
ance regarding the reporting requirements for interest paid to
the U.S. accounts of certain nonresident alien individuals. The
reporting required by these final regulations will support the
U.S. government’s efforts to combat offshore tax evasion.
Notice 2012–32, page 910.
This notice requests comments on information reporting under
section 6055 of the Code by health insurance issuers, govern-
ment agencies, employers that sponsor self-insured plans, and
other persons that provide minimum essential coverage to an
individual.
Notice 2012–33, page 912.
This notice invites comments on reporting under section 6056
of the Code by applicable large employers (as defined in section
4980H(c)(2)) that are subject to section 4980H. Section 6056
requires reporting of certain information on employer-provided
health care coverage provided on or after January 1, 2014.
The notice also advises the public that the Treasury and IRS
intend to propose regulations implementing section 6056 and
invites comments on issues arising under section 6056, includ-
ing on possible approaches for coordinating and minimizing du-
plication between the information required to be reported and
furnished by employers under section 6056 and information re-
quired to be reported and/or furnished by employers or other
persons under other applicable Code provisions.
Rev. Proc. 2012–24, page 913.
This procedure provides guidance for implementing final regu-
lations under section 6049 of the Code. The procedure con-
tains two lists of countries with which the IRS has an income
tax or other convention or bilateral agreement relating to the
exchange of information for tax administration purposes.
Rev. Proc. 2012–25, page 914.
This procedure provides issuers of qualified mortgage bonds
(QMBs) and qualified mortgage credit certificates (MCCs) with
average area purchase price safe harbors for statistical areas
in the United States and with a nationwide average purchase
price for residences in the United States for purposes of the
QMB rules under section 143 of the Code and the MCC rules
under section 25. Rev. Proc. 2011–23 obsoleted in part.
May 14, 20122012–20 I.R.B.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
2012–20 I.R.B.May 14, 2012

May 14, 20122012–20 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 6049.—Returns
Regarding Payments
of Interest
26 CFR 1.6049–4: Return of information as to in-
terest paid and original issue discount includible in
gross income after December 31, 1982.
T.D. 9584
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Parts 1 and 31
Guidance on Reporting
Interest Paid to Nonresident
Aliens
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final Regulations.
SUMMARY: This document contains fi-
nal regulations regarding the reporting re-
quirements for interest that relates to de-
posits maintained at U.S. offices of certain
financial institutions and is paid to certain
nonresident alien individuals. These regu-
lations will affect commercial banks, sav-
ings institutions, credit unions, securities
brokerages, and insurance companies that
pay interest on deposits.
DATES:Effective Date:These regulations
are effective April 19, 2012.
Applicability Date:These regulations
apply to payments of interest made on or
after January 1, 2013.
FOR FURTHER INFORMATION
CONTACT: Kathryn Holman, (202)
622–3840 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in these final regulations has been
reviewed and approved by the Office of
Management and Budget for review in
accordance with the Paperwork Reduction
Act of 1995 (44 U.S.C. 3507(d)) under
control number 1545–1725. The col-
lection of information in these proposed
regulations is in §1.6049–4(b)(5)(i) and
§1.6049–6(e)(4)(i) and (ii). The collec-
tion of information is mandatory and the
respondents are commercial banks, sav-
ings institutions, credit unions, securities
brokerages, and insurance companies that
maintain deposit accounts for nonresident
alien individuals.
An agency may not conduct or sponsor,
and a person is not required to respond to, a
collection of information unless it displays
a valid control number assigned by the Of-
fice of Management and Budget.
Books or records relating to a collection
of information must be retained as long as
their contents may become material in the
administration of any internal revenue law.
Information collected under these regula-
tions will be return information as defined
in 26 U.S.C. 6103. Tax returns and return
information are confidential as required by
26 U.S.C. 6103.
Background
On January 7, 2011, the Treasury De-
partment and the IRS published a notice of
proposed rulemaking (REG–146097–09,
2011–8 I.R.B. 516) (the 2011 proposed
regulations) in theFederal Register(76
FR 1105, corrected by 76 FR 2852, 76 FR
20595, and 76 FR 22064) under section
6049 of the Internal Revenue Code (Code).
The 2011 proposed regulations withdrew
proposed regulations that had been
issued on August 2, 2002 (67 FR 50386)
(the 2002 proposed regulations). The
2002 proposed regulations would have
required reporting of interest payments
to nonresident alien individuals that are
residents of certain specified countries.
The 2011 proposed regulations provide
that payments of interest aggregating $10
or more on a deposit maintained at a U.S.
office of a financial institution and paid
to any nonresident alien individual are
subject to information reporting.
Written comments were received
by the Treasury Department and the
IRS in response to the 2011 proposed
regulations. A public hearing on the
2011 proposed regulations was held on
May 18, 2011, at which further comments
were received. All comments were
considered and are available for public
inspection athttp://www.regulations.gov
or upon request. After consideration of
the written comments and the comments
provided at the public hearing, the 2011
proposed regulations are adopted as
revised by this Treasury decision.
Explanation and Summary of
Comments
Objectives of This Regulatory Action
The reporting required by these regula-
tions is essential to the U.S. Government’s
efforts to combat offshore tax evasion for
several reasons. First, it ensures that the
IRS can, in appropriate circumstances, ex-
change information relating to tax enforce-
ment with other jurisdictions. In order to
ensure that U.S. taxpayers cannot evade
U.S.taxbyhidingincomeandassetsoff-
shore, the United States must be able to ob-
tain information from other countries re-
garding income earned and assets held in
those countries by U.S. taxpayers. Un-
der present law, the measures available to
assist the United States in obtaining this
information include both treaty relation-
ships and statutory provisions. The effec-
tiveness of these measures depends signifi-
cantly, however, on the United States’ abil-
ity to reciprocate.
The United States has constructed an
expansive network of international agree-
ments, including income tax or other
conventions and bilateral agreements re-
lating to the exchange of tax information
(collectively referred to as information
exchange agreements), which provide for
the exchange of information related to
tax enforcement under appropriate cir-
cumstances. These information exchange
relationships are based on cooperation and
reciprocity. A jurisdiction’s willingness to
shareinformationwiththeIRStocombat
offshore tax evasion by U.S. taxpayers
depends, in large part, on the ability of
the IRS to exchange information that will
assist that jurisdiction in combating off-
shore tax evasion by its own residents.
These regulations, by requiring reporting
of deposit interest to the IRS, will ensure
2012–20 I.R.B.900May 14, 2012

that the IRS is in a position to exchange
such information reciprocally with a treaty
partner when it is appropriate to do so.
Second, in 2010, Congress supple-
mented the established network of infor-
mation exchange agreements by enacting,
as part of the Hiring Incentives to Restore
Employment Act of 2010 (Public Law 111
–147), provisions commonly known as
the Foreign Account Tax Compliance Act
(FATCA) that require overseas financial
institutions to identify U.S. accounts and
report information (including interest pay-
ments) about those accounts to the IRS. In
many cases, however, the implementation
of FATCA will require the cooperation of
foreign governments in order to overcome
legal impediments to reporting by their
resident financial institutions. Like the
United States, those foreign governments
are keenly interested in addressing off-
shore tax evasion by their own residents
and need tax information from other ju-
risdictions, including the United States,
to support their efforts. These regulations
will facilitate intergovernmental coopera-
tion on FATCA implementation by better
enabling the IRS, in appropriate circum-
stances, to reciprocate by exchanging
information with foreign governments for
tax administration purposes.
Finally, the reporting of information
required by these regulations will also
directly enhance U.S. tax compliance by
making it more difficult for U.S. taxpayers
with U.S. deposits to falsely claim to be
nonresidents in order to avoid U.S. taxa-
tion on their deposit interest income.
International Standard for Transparency
and Information Exchange
Under the international standard for
transparency and exchange of information,
which is reflected in the Organisation for
Economic Cooperation and Development
(OECD) Model Agreement on Exchange
of Information on Tax Matters, the OECD
Model Tax Convention, and the United
Nations Model Double Tax Conven-
tion between Developed and Developing
Countries, exchange of tax information
cannot be limited by domestic bank se-
crecy laws or the absence of a specific
domestic tax interest in the information
to be exchanged. Accordingly, under this
global standard a country cannot refuse to
share tax information based on domestic
laws that do not require banks to share
the information. In addition, under the
global standard, a country cannot opt out
of information exchange based on the fact
that the country does not itself need the
information to enforce its own tax rules.
Thus, even countries that do not impose
income taxes, and therefore do not have
tax enforcement concerns, have entered
into information exchange agreements to
provide information about the accounts of
nonresidents.
Comments Regarding Confidentiality and
Improper Use of Information
Some comments on the 2011 proposed
regulations expressed concerns that the
information required to be reported under
those regulations might be misused. For
example, comments expressed concern
that deposit interest information may be
shared with a country that does not have
laws in place to protect the confidential-
ity of the information exchanged or that
would use the information for purposes
other than the enforcement of its tax laws.
These comments further suggested that
these concerns could affect nonresident
alien investors’ decisions about the loca-
tion of their deposits.
The Treasury Department and the IRS
believe that the concerns raised by the
comments are addressed by existing legal
limitations and administrative safeguards
governing tax information exchange. As
discussed herein, information reported
pursuant to these regulations will be ex-
changed only with foreign governments
with which the United States has an agree-
ment providing for the exchange and when
certain additional requirements are satis-
fied. Even when such an agreement exists,
the IRS is not compelled to exchange in-
formation, including information collected
pursuant to these regulations, if there is
concern regarding the use of the informa-
tion or other factors exist that would make
exchange inappropriate.
First, information reported pursuant to
these regulations is return information un-
der section 6103. Section 6103 imposes
strict confidentiality rules with respect to
all return information. Moreover, section
6103(k)(4) allows the IRS to exchange re-
turn information with a foreign govern-
ment only to the extent provided in, and
subject to the terms and conditions of an
information exchange agreement. Thus,
the IRS can share the information reported
under these regulations only with foreign
governments with which the United States
has an information exchange agreement.
Absent such an agreement, the IRS is statu-
torily barred from sharing return informa-
tion with another country, and these regu-
lations cannot and do not change that rule.
Second, consistent with established
international standards, all of the infor-
mation exchange agreements to which the
United States is a party require that the
information exchanged under the agree-
ment be treated and protected as secret
by the foreign government. In addition,
information exchange agreements gener-
ally prohibit foreign governments from
using any information exchanged under
such an agreement for any purpose other
than the purpose of administering, collect-
ing, and enforcing the taxes covered by
the agreement. Accordingly, under these
agreements, neither country is permitted
to release the information shared under
the agreement or use it for any other law
enforcement purposes.
Third, consistent with the international
standard for information exchange and
United States law, the United States will
not enter into an information exchange
agreement unless the Treasury Department
and the IRS are satisfied that the foreign
government has strict confidentiality pro-
tections. Specifically, prior to entering
into an information exchange agreement
with another jurisdiction, the Treasury
Department and the IRS closely review
the foreign jurisdiction’s legal framework
for maintaining the confidentiality of tax-
payer information. In order to conclude
an information exchange agreement with
another country, the Treasury Department
and the IRS must be satisfied that the for-
eign jurisdiction has the necessary legal
safeguards in place to protect exchanged
information and that adequate penalties
apply to any breach of that confidentiality.
Finally, even if an information ex-
change agreement is in effect, the IRS
will not exchange information on deposit
interest or otherwise with a country if the
IRS determines that the country is not
complying with its obligations under the
agreement to protect the confidentiality
of information and to use the information
solely for collecting and enforcing taxes
covered by the agreement. The IRS also
May 14, 20129012012–20 I.R.B.

will not exchange any return information
with a country that does not impose tax
on the income being reported because the
information could not be used for the en-
forcement of tax laws within that country.
In addition, the IRS has options regard-
ing the appropriate form of exchange. For
example, the IRS might exchange infor-
mation with another jurisdiction only upon
specific request. In the case of specific ex-
change requests, the IRS evaluates the re-
questing country’s current practices with
respect to information confidentiality. The
IRS also requires the requesting country
to explain the intended permitted use of
the information and justify the relevance of
that information to the permitted use. Al-
ternatively, in appropriate circumstances,
the IRS might exchange certain informa-
tion on an automatic basis. The IRS cur-
rently exchanges deposit interest informa-
tion on an automatic basis with only one
jurisdiction (Canada). The IRS will not
enter into a new automatic exchange re-
lationship with a jurisdiction unless it has
reviewed the country’s policies and prac-
tices and has determined that such an ex-
change relationship is appropriate. Fur-
ther, the IRS generally will not enter into
an automatic exchange relationship with
respect to the information collected under
these regulations unless the other jurisdic-
tion is willing and able to reciprocate ef-
fectively.
The Treasury Department and the IRS
believe that the legal and administrative
safeguards described in the preceding
paragraphs regarding the use of infor-
mation collected under these regulations
should adequately address the concerns
identified by the comments and, therefore,
these regulations should not significantly
impact the investment and savings deci-
sions of the vast majority of nonresidents
who are aware of and understand these
safeguards and existing law and prac-
tice. Nevertheless, to enhance awareness
and further address concerns, these final
regulations revise the 2011 proposed regu-
lations to require reporting only in the case
of interest paid to a nonresident alien indi-
vidual resident in a country with which the
United States has in effect an information
exchange agreement pursuant to which the
United States agrees to provide, as well as
receive, information and under which the
competent authority is the Secretary of the
Treasury or his delegate.
For this purpose, the Treasury Depart-
ment and the IRS will publish a Revenue
Procedure contemporaneously with these
final regulations specifically identifying
the countries with which the United States
has in force such an information exchange
agreement. The Revenue Procedure will
be updated as appropriate. With respect
to any calendar year, payors will only
be required to report interest on deposits
maintained at an office within the United
States and paid to a nonresident alien in-
dividual who is a resident of a country
identified in the Revenue Procedure as of
December 31 of the prior calendar year
as being a country with which the United
States has in effect such an information
exchange agreement. To address any po-
tential burden associated with reporting
on this basis, the final regulations provide
that for any year for which the information
return under §1.6049–4(b)(5) is required,
a payor may elect to report interest pay-
ments to all nonresident alien individuals.
As previously discussed, the identifi-
cation of a country as having an informa-
tion exchange agreement with the United
States does not necessarily mean that the
information collected under these regu-
lations will be reported to such foreign
jurisdiction. As an additional measure to
further increase awareness among con-
cerned nonresidents regarding the IRS’
use of information collected under these
regulations, the Revenue Procedure also
will include a second list identifying the
countries with which the Treasury De-
partment and the IRS have determined
that it is appropriate to have an automatic
exchange relationship with respect to the
information collected under these regu-
lations. This determination will be made
only after further assessment of a coun-
try’s confidentiality laws and practices and
the extent to which the country is willing
and able to reciprocate.
In addition, in response to comments,
and given the information exchange prac-
tices described in the preceding paragraphs
and the information that will be available
in the Revenue Procedure, these final reg-
ulations eliminate the requirement in the
2011 proposed regulations for financial
institutions to include in the informa-
tion statement provided to nonresident
alien individuals a statement informing
the individual that the information may
be furnished to the government of the
country where the recipient resides. In ad-
dition, these final regulations clarify that a
payor or middleman may rely on the per-
manent residence address provided on a
valid Form W–8BEN, “Beneficial Owners
Certificate of Foreign Status for U.S. Tax
Withholding”, for purposes of determining
the country of residence of a nonresident
alien to whom reportable interest is paid
unless the payor or middleman knows
or has reason to know that such docu-
mentation of the country of residence is
unreliable or incorrect. The final regula-
tions also modify §31.3406(g)–1 of the
proposed regulations to clarify that, con-
sistent with the backup withholding rules
generally, a payment of interest described
in §1.6049–8(a) is not subject to withhold-
ing under section 3406 if the payor may
treat the payee as a foreign person, without
regard to whether the payor reported such
interest (although a payor may be subject
to penalties if it fails to report as required).
As under the prior regulations requiring
the reporting of interest paid to Canadian
non-resident alien individuals, the final
regulations define interest subject to re-
porting to mean interest paid on deposits
as defined under section 871(i)(2)(A) (in-
cluding deposits with persons carrying on
a banking business, deposits with certain
savings institutions, and certain amounts
held by insurance companies under agree-
ments to pay interest thereon).
Comments Regarding Authority and
Congressional Intent
Some comments expressed the view
that the Treasury Department and the IRS
lack the authority to require the report-
ing required under the 2011 proposed
regulations, or that the 2011 proposed
regulations are contrary to Congressional
intent. The relevant statutory provisions
expressly contemplate that the Treasury
Department and the IRS have authority to
require reporting on deposit interest paid
to nonresidents. Section 6049(a) provides
generally for reporting with respect to
interest payments. Section 6049(b)(2)(B)
and (5) provides that, except to the extent
otherwise provided in regulations, re-
portable interest does not include interest
paid to nonresident alien individuals on
deposits described in section 871(i)(2)(A).
Section 6049(b)(2)(B) and (5) thus pro-
vides express authority for the Treasury
2012–20 I.R.B.902May 14, 2012

Department and the IRS to issue regula-
tions requiring reporting of such interest.
Special Analyses
It has been determined that these reg-
ulations are not a significant regulatory
action as defined in Executive Order
12866, as supplemented by Executive
Order 13563. Therefore, a regulatory
assessment is not required. It also has
been determined thatsection 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions.
When an agency promulgates a fi-
nal rule, the Regulatory Flexibility Act,
5 U.S.C. chapter 6 (RFA), requires the
agency to prepare a final regulatory flexi-
bility analysis describing the impact of the
final rule on small entities. 5 U.S.C. 604.
Section 605 of the RFA allows an agency
to certify a rule, in lieu of preparing a
regulatory flexibility analysis, if the final
rule is not expected to have a significant
economic impact on a substantial number
of small entities.
These regulations impose a collection
of information, and thus, the Regulatory
Flexibility Act (5 U.S.C. chapter 6) ap-
plies. It is hereby certified that the col-
lection of information contained in these
regulations will not have a significant eco-
nomic impact on a substantial number of
small entities.
The preamble to the 2011 proposed reg-
ulations sets forth an analysis of the num-
ber of small entities that may be required to
report under these regulations. Although
this rule may affect a substantial number of
small entities, the IRS has determined that
the impact on entities affected by these fi-
nal regulations will not be significant.
Some comments expressed concern
that the regulations would impose a new
administrative burden on U.S. financial
institutions. In addition, some comments
objected that collecting and reporting this
information imposes burdens on certain
types of financial institutions, including
community banks and banks in certain
states that have a larger percentage of
customers who are nonresident alien indi-
viduals.
The Treasury Department and the IRS
disagree. Under existing law, all U.S. fi-
nancial institutions have responsibilities to
withhold on and report with respect to de-
positors who are U.S. citizens, U.S. resi-
dent individuals, and Canadian resident in-
dividuals, and have developed the systems
to perform such withholding and reporting.
All nonresident alien individual ac-
count holders who maintain accounts in
the United States are already required to
complete a Form W–8BEN, declaring their
non-U.S. status and the country in which
they reside. U.S. financial institutions
can use their existing W–8 information to
produce Form 1042–S disclosures for the
relevant nonresident alien individual ac-
count holders. Nearly all U.S. banks and
other financial institutions have automated
systems to produce Form 1099–INT, “In-
terest Income”, for U.S. accountholders
and Form 1042–S, “Foreign Person’s U.S.
Source Income Subject to Withholding”,
for Canadian accountholders. As a result,
the information collection requirements in
these regulations build on reporting and
information collection systems familiar to
and currently used by U.S. financial insti-
tutions, including small business entities.
Theamountoftimerequiredtocomplete
the Form 1042 and Form 1042–S is min-
imal, and the statement that is required
to be collected is brief. Accordingly, it
should not be a significant burden to adapt
those systems to report with respect to
depositors who are resident in other coun-
tries with which the United States has an
information exchange agreement. There-
fore, a regulatory flexibility analysis is not
required.
Pursuant to section 7805(f) of the Code,
the notice of proposed rulemaking preced-
ing these final regulations was submitted
to the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on its impact on small businesses.
The Chief Counsel for Advocacy of the
Small Business Administration did not
comment on the notice of proposed rule-
making.
Drafting Information
The principal author of the regulations
is Kathryn Holman, Office of Associate
Chief Counsel (International). However,
other personnel from the Treasury
Department and the IRS participated in
their development.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1 and 31 are
amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority26U.S.C.7805***
Par. 2. In §1.6049–4, paragraph (b)(5)
is revised to read as follows:
§1.6049–4 Return of information as
to interest paid and original issue
discount includible in gross income after
December 31, 1982.
(b) * * *
(5)Interest payments to certain nonres-
ident alien individuals—(i)General rule.
In the case of interest aggregating $10 or
more paid to a nonresident alien individ-
ual (as defined in section 7701(b)(1)(B))
that is reportable under §1.6049–8(a), the
payor shall make an information return
on Form 1042–S, “Foreign Person’s U.S.
Source Income Subject to Withholding,”
for the calendar year in which the inter-
est is paid. The payor or middleman shall
prepare and file Form 1042–S at the time
and in the manner prescribed by section
1461 and the regulations under that sec-
tion and by the form and its accompany-
ing instructions. See §§1.1461–1(b) (rules
regarding the preparation of a Form 1042)
and 1.6049–6(e)(4) (rules for furnishing a
copy of the Form 1042–S to the recipient).
To determine whether an information re-
turn is required for original issue discount,
see §§1.6049–5(f) and 1.6049–8(a).
(ii)Effective/applicability date. Para-
graph (b)(5)(i) of this section shall be ap-
plicable for payments made on or after Jan-
uary 1, 2013. (For interest paid to a Cana-
dian nonresident alien individual on or be-
fore December 31,2012, see paragraph
(b)(5) of this section as in effect and con-
tained in 26 CFR part 1 revised April 1,
2000.)
*****
Par. 3. Section 1.6049–5 is amended as
follows:
1. In paragraph (b)(12), the last sen-
tence is revised.
2. In paragraph (f), the last sentence is
revised.
The revisions read as follows:
May 14, 20129032012–20 I.R.B.

§1.6049–5 Interest and original issue
discount subject to reporting after
December 31, 1982.
*****
(b) * * *
(12) * * * This paragraph (b)(12) does
notapplytointerestpaidonorafterJan-
uary 1, 2013, to a nonresident alien indi-
vidual to the extent provided in §1.6049–8.
*****
(f) * * * Original issue discount on an
obligation (including an obligation with a
maturity of not more than six months from
the date of original issue) held by a non-
resident alien individual or foreign corpo-
ration is interest described in paragraph
(b)(1)(vi)(A) or (B) of this section and,
therefore is not interest subject to reporting
under section 6049 unless it is described
in §1.6049–8(a) (relating to deposit inter-
est paid on or after January 1,2013, to cer-
tain nonresident alien individuals).
*****
Par. 4. Section 1.6049–6 is amended as
follows:
1. The paragraph heading and text of
paragraph (e)(4) is revised.
2. In paragraph (e)(5), the paragraph
heading and first sentence are revised and
a new sentence is added at the end of the
paragraph.
The additions and revisions read as fol-
lows:
§1.6049–6 Statements to recipients
of interest payments and holders of
obligations for attributed original issue
discount.
*****
(e) * * *
(4)Special rule for amounts described
in §1.6049–8(a).In the case of amounts
described in §1.6049–8(a) (relating to
payments of deposit interest to certain
nonresident alien individuals) paid on
or after January 1, 2013, any person
who makes a Form 1042–S, “Foreign
Person’s U.S. Source Income Subject to
Withholding,” under section 6049(a) and
§1.6049–4(b)(5) shall furnish a statement
to the recipient either in person or by first
class mail to the recipient’s last known
address. The statement shall include a
copy of the Form 1042–S required to be
prepared pursuant to §1.6049–4(b)(5) and
a statement to the effect that the informa-
tion on the form is being furnished to the
United States Internal Revenue Service.
(5)Effective/applicability date. Para-
graph (e)(4) of this section applies to payee
statements reporting payments of deposit
interest to nonresident alien individuals
paid on or after January 1, 2013. * * * (For
interest paid to a Canadian nonresident
alien individual on or before December 31,
2012, see paragraph (e)(4) of this section
as in effect and contained in 26 CFR part
1 revised April 1, 2000.)
Par. 5. In §1.6049–8, the section head-
ing and paragraph (a) are revised to read as
follows:
§1.6049–8 Interest and original issue
discount paid to certain nonresident
aliens.
(a)Interest subject to reporting re-
quirement. For purposes of §§1.6049–4,
1.6049–6, and this section, and except as
provided in paragraph (b) of this section,
the terminterestmeans interest described
in section 871(i)(2)(A) that relates to a
deposit maintained at an office within the
United States, and that is paid to a nonresi-
dent alien individual who is a resident of a
country that is identified, in an applicable
revenue procedure (see §601.601(d)(2) of
this chapter) as of December 31 prior to
the calendar year in which the interest is
paid, as a country with which the United
States has in effect an income tax or other
convention or bilateralagreement relating
to the exchange of tax information within
the meaning of section 6103(k)(4), un-
der which the competent authority is the
Secretary of the Treasury or his delegate
and the United States agrees to provide,
as well as receive, information. Notwith-
standing the foregoing, for purposes of
§§1.6049–4, 1.6049–6, and this section,
for any year for which the information
return under §1.6049–4(b)(5) is required,
a payor may elect to treat interest as in-
cluding all interest described in section
871(i)(2)(A) that relates to a deposit main-
tained at an office within the United States
and that is paid to any nonresident alien
individual. A payor shall make this elec-
tion by reporting all such interest. For
purposes of the regulations under section
6049 (§§1.6049–1 through 1.6049–8), a
nonresident alien individual is a person
described in section 7701(b)(1)(B). A
payor or middleman may rely upon the
permanent residence address provided on
avalidFormW–8BEN,“Beneficial Own-
ers Certificate of Foreign Status for U.S.
Tax Withholding”, to determine the coun-
try in which a nonresident alien individual
is resident unless such payor or middle-
man knows or has reason to know that
such documentation of the country of res-
idence is unreliableor incorrect. Amounts
described in this paragraph (a) are not sub-
ject to backup withholding under section
3406 if the payor may treat the payee as a
foreign beneficial owner or foreign payee
under the rules of §1.6049–5(b)(12). See
§31.3406(g)–1(d) of this chapter. How-
ever, if the payor or middleman does not
have either a valid Form W–8BEN or
valid Form W–9, “Request for Taxpayer
Identification Number and Certification”,
the payor or middleman must report the
payment as made to a U.S. non-exempt
recipient if it must so treat the payee under
the presumption rules of §1.6049–5(d)(2)
and §1.1441–1(b)(3)(iii), and the payor
must also backup withhold under section
3406. (For interest paid to a Canadian
nonresident alien individual on or before
December 31, 2012, see paragraph (a) of
this section as in effect and contained in
26 CFR part 1 revised April 1, 2000).
*****
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME TAX
AT THE SOURCE
Par. 6. The authority citation for part
31 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 7. In §31.3406(g)–1, paragraph (d)
is revised to read as follows:
§31.3406(g)–1 Exception for payments
to certain payees and certain other
payments.
*****
(d)Reportable payments made to non-
resident alien individuals.Apayment
of interest to a nonresident alien individ-
ual that is described in §1.6049–(8)(a) of
this chapter is not subject to withhold-
ing under section 3406 if the payor may
treat the payee as a foreign beneficial
owner or foreign payee under the rules
of §1.6049–5(b)(12). (For interest paid
2012–20 I.R.B.904May 14, 2012

to a Canadian nonresident alien individ-
ual on or before December 31,2012, see
paragraph (d) of this section as in effect
and contained in 26 CFR part 1 revised
April 1, 2000.)
*****
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved April 12, 2012.
Emily S. McMahon,
(Acting) Assistant Secretary
oftheTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on April 17, 2012,
4:15 p.m., and published in the issue of the Federal Register
for April 19, 2012, 77 F.R. 23391)
May 14, 20129052012–20 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Minimum Value of an
Employer-Sponsored Health
Plan
Notice 2012–31
I. PURPOSE AND OVERVIEW
This notice describes and requests
comments on several possible approaches
to determining whether health coverage
under an eligible employer-sponsored
plan, as defined in § 5000A of the In-
ternal Revenue Code (“employer-spon-
sored plan”), provides minimum value
within the meaning of § 36B(c)(2)(C)(ii).
Beginning in 2014, eligible individuals
who purchase coverage under a quali-
fied health plan through an Affordable
Insurance Exchange may receive a pre-
mium tax credit under § 36B unless they
are eligible for other minimum essential
coverage, including coverage under an
employer-sponsored plan that is affordable
to the employee and provides minimum
value. Under § 36B(c)(2)(C)(ii), a plan
fails to provide minimum value if “the
plan’s share of the total allowed costs of
benefits provided under the plan is less
than 60 percent of such costs.” If the
coverage offered by the employer fails
to provide minimum value, an employee
may be eligible to receive a premium tax
credit. An applicable large employer (as
defined in § 4980H(c)(2)) may be liable
for an assessable payment under § 4980H
if any full-time employee receives a pre-
mium tax credit.
The Treasury Department and the In-
ternal Revenue Service intend to issue
proposed regulations on determining mini-
mum value and are considering incorporat-
ing the approach described in this notice.
As described below, under anticipated
future guidance, an employer-sponsored
plan would be able to use one of several
alternative approaches to ascertain that the
plan provides minimum value. Specifi-
cally, this notice seeks comment on the
following three potential approaches that
could be used to determine whether an
employer-sponsored plan provides mini-
mum value:
•The actuarial value calculator (AV
calculator), referred to below, or a
minimum value calculator (MV cal-
culator) to be made available by the
Department of Health and Human
Services (HHS) and the Treasury De-
partment. In eithercase, the calculator
would permit an employer-sponsored
plan to enter information about the
plan’s benefits, coverage of services,
and cost-sharing terms to determine
whether the plan provides minimum
value. The data underlying the MV
calculator (which would be designed
for use by employer-sponsored self-in-
sured plans and insured large group
plans) are expected to be claims data
reflecting typical self-insured em-
ployer plans.
•An array of design-based safe harbors
in the form of checklists that would
provide a simple, straightforward way
to ascertain that employer-sponsored
plans provide minimum value without
the need to perform any calculations or
obtain the assistance of an actuary.
•For plans with nonstandard features
that preclude the use of the AV cal-
culator or the MV calculator without
adjustments, an appropriate certifi-
cation by a certified actuary, in ac-
cordance with prescribed continuance
tables, recognized actuarial standards,
and other conditions that may be pre-
scribed in administrative guidance,
that the plan provides minimum value.
Section VI of this notice describes these
potential approaches in greater detail.
Under the statute, certain of the
rules for determining whether an
employer-sponsored plan provides
minimum value are to be based on
forthcoming regulations to be issued by
HHS that will specify the methods for
determining the actuarial value of a
qualified health plan (QHP) offered
through an Affordable Insurance
Exchange and non-grandfathered plans
in the individual and small group
markets.On February 24, 2012,
HHS issued the “Actuarial Value
and Cost-Sharing Bulletin” (HHS
actuarial value bulletin) describing the
assumptions and methodology that
HHS anticipates will govern the
calculation of actuarial value.
1
(See
http://cciio.cms.gov/resources/files/Files2/
02242012/Av-csr-bulletin.pdf.)This
notice describes how guidance issued
by HHS on the determination of
actuarial value is expected to be applied
in determining minimum value. This
notice also outlines ways in which the
determination of minimum value is
expected to differ from the determination
of the actuarial value of QHPs in
order to reflect differences between
QHPs and employer-sponsored plans,
such as differences in their levels of
standardization and the populations
covered.
Employer-sponsored self-insured and
insured large group plans are not required
to conform their plans to any of the es-
sential health benefit (EHB) benchmarks
that HHS intends to propose to apply to
QHPs.
2
These employer-sponsored plans
need not offer all of the EHBs or even
cover each of the ten statutory EHB cate-
gories.
This notice provides information re-
garding the actuarial value of existing
employer-sponsored plans (Section II)
and the statutory background of the pre-
mium tax credit and the minimum value
provision (Section III). The notice then
describes, by way of background, the in-
tended methodology laid out in the HHS
actuarial value bulletin for determining
the actuarial value of a QHP (Section
IV) and explains the assumptions ex-
pected to be used to determine whether an
employer-sponsored plan meets the min-
imum value threshold (Section V). The
notice describes the options that are being
considered for determining whether an
employer-sponsored plan has an actuarial
value of at least 60 percent and therefore
provides minimum value (Section VI).
1
The actuarial value rules under § 1302(d) and the essential health benefit provision under § 1302(b) apply to QHPs offered on an Affordable Insurance Exchange and also to non-grandfathered
plans in the individual and small group insurance market. See § 2707(a) of the Public Health Service Act, as added by § 1201 of the Affordable Care Act, which provides that non-grandfathered
plans in the individual and small group insurancemarkets must cover the “essential health benefits package,” as defined in § 1302(a) of the AffordableCareAct.
2
The EHB benchmarks that HHS intends to propose also apply to non-grandfathered plans in the individual and small group insurance markets.
2012–20 I.R.B.906May 14, 2012

Finally, the notice also invites public com-
ments (Section VII).
II. ACTUARIAL VALUE OF EXISTING
EMPLOYER-SPONSORED PLANS
The actuarial value of a health plan
is a measure of the percentage of health
care costs, on average, that the plan is
expected to cover. A report issued last
fall by HHS found that approximately 98
percent of individuals currently covered
by employer-sponsored plans are enrolled
in plans that have an actuarial value of
at least 60 percent using methods and
assumptions similar to those described
in this notice for determining minimum
value. (See Actuarial Value and Em-
ployer-Sponsored Insurance, ASPE Re-
search Brief, U.S. Department of Health
and Human Services (November 2011)
http://aspe.hhs.gov/health/reports/2011/
AV-ESI/rb.shtml.) The HHS report also
concludes that four core categories
of benefits and services are the
greatest contributors to a health plan’s
actuarial value: physician and mid-level
practitioner care; hospital and emergency
room services; pharmacy benefits; and
laboratory and imaging services. Because
they account for only a very small portion
of overall medical expenditures, benefits
and services beyond these four core
categories of benefits that are covered by a
plan generally have only a limited impact
on the plan’s actuarial value. For example,
a plan that does not include coverage for
rehabilitative services, durable medical
equipment, acupuncture and chiropractic
services, and home health services may
have an actuarial value that is only 5
percent less than a plan that includes
coverage for these services. (See ASPE
Research Brief.) We seek input on whether
other analyses using different data or
assumptions produce similar or different
results.
III. STATUTORY BACKGROUND
Section 36B was added by § 1401 of
the Patient Protection and Affordable Care
Act, Public Law 111–148, and modified
by the Health Care and Education Recon-
ciliation Act of 2010, Public Law 111–152
(collectively, the Affordable Care Act).
Beginning in 2014, certain taxpayers are
allowed a refundable premium tax credit
under § 36B to assist in purchasing QHP
coverage through an Affordable Insurance
Exchange. The premium tax credit is
designed to make QHP coverage afford-
able by reducing an eligible taxpayer’s
out-of-pocket premium cost. (Under
§ 1402 of the Affordable Care Act, eligi-
ble individuals are entitled to an advance
payment of the premium tax credit, which
is paid directly to the QHP issuer selected
by the individual.)
An employee, or a member of the
employee’s family, who is eligible to
enroll in an employer-sponsored plan
is not eligible for a premium tax credit
unless the plan’s coverage for the em-
ployee either is unaffordable, as defined
in § 36B(c)(2)(C)(i)(II), or does not
provide minimum value, as defined in
§ 36B(2)(c)(2)(C)(ii). An employee (or
member of the employee’s family) also is
not eligible if he or she actually enrolls
in the employer-sponsored plan, even if
the plan is not affordable or fails to pro-
vide minimum value. Under § 4980H, an
“applicable large employer” is generally
liable for an assessable payment if any
full-time employee receives a premium
tax credit.
To satisfy the minimum value require-
ment under § 36B(c)(2)(C)(ii), a plan’s
share of the “total allowed costs of bene-
fits provided under the plan” must equal or
exceed 60 percent of such costs. Section
1302(d)(2)(C) of the Affordable Care Act
directs that the statutory phrase — “per-
centage of the total allowed costs of bene-
fits provided under a group health plan” —
is determined under rules contained in the
regulations to be promulgated by HHS un-
der § 1302(d)(2) (titled “Actuarial Value”).
The requirements applicable to these HHS
regulations are set forth in subparagraphs
(A) and (B) of § 1302(d)(2).
3
Consistent
with these statutory requirements, the de-
termination of whether an employer-spon-
sored plan provides minimum value will
be based on the actuarial value rules with
appropriate modifications.
Subparagraph (B) of § 1302(d)(2) re-
quires HHS to issue regulations under
which employer contributions to a health
savings account (HSA) may be taken
into account in determining the actuarial
value of an employer-sponsored plan. In
addition, § 1302(d)(3) of the Affordable
Care Act authorizes the Secretary of HHS
to determine a reasonable “de minimis”
variation in the actuarial values used in
determining the level of coverage of a
plan to account for differences in actuarial
estimates.
IV. HHS INTENTIONS WITH RESPECT
TO ACTUARIAL VALUE FOR
QUALIFIED HEALTH PLANS
The HHS actuarial value bulletin ex-
plains that, in accordance with the require-
ments of subparagraph (A) of § 1302(d)(2)
of the Affordable Care Act, the actuar-
ial value of QHPs offered through an
Affordable Insurance Exchange (and of
non-grandfathered plans in the individual
and small group insurance markets) is
determined by computing the ratio of (1)
the total expected payments by the plan,
computed in accordance with the plan’s
cost-sharing rules (deductibles, co-insur-
ance, co-payments, out-of-pocket limits),
toward the costs a standard population is
expected to incur at standard pricing for
EHBs; over (2) the total costs a standard
population is expectedto incur at standard
pricing for the EHBs.
4
This actuarial value
is used to determine the “metal level” of
a QHP (that is, platinum, gold, silver, or
bronze). For example, bronze plans must
have a 60 percent actuarial value.
HHS announced that it intends to make
available to the public an AV calculator
that could be used to determine the ac-
tuarial value of QHPs (and non-grandfa-
thered plans in the individual and small
group insurance markets). The AV cal-
culator would be designed so that issuers
3
Subparagraph (A) of § 1302(d)(2) requires the level of coverage of a plan to be “determined on the basis that the essential health benefits described insubsection [1302](b) shall be provided
to a standard population. . . .”
4
On December 16, 2011, HHS issued the “Essential Health Benefits Bulletin,” which outlined the approach HHS plans to use to define the EHBs.(See
http://cciio.cms.gov/resources/files/Files2/12162011/essential_health_benefits_bulletin.pdf.) Under this approach, each state would have the flexibility to select a “benchmark plan” from a
list of permissible options specified by HHS in the bulletin. The scope of benefits provided under the state-specific benchmark plan would determinethe scope of EHBs for QHPs in that
state. In addition, the EHBs must encompass the ten categories of benefits listed in § 1302(a) of the Affordable Care Act. If the benchmark plan in a state does not offer coverage in each of
the ten categories, the bulletin provides an intended method for supplementing deficient categories of benefits so all QHPs in the state would include benefits in all ten categories. The
bulletin also provides an intended method for determining the benchmark plan in a state if the state fails to make a selection.
May 14, 20129072012–20 I.R.B.

would be able to input a limited set of in-
formation on the benefits provided under
the plan, and the calculator would provide
the actuarial value of the plan. The claims
data underlying the AV calculator would
represent the entire range of EHB bench-
mark benefits that states would be permit-
ted to select.
Although HHS anticipates that the
overwhelming majority of issuers of QHPs
would be able to calculate the actuarial
value of their health plans using the AV
calculator, HHS requested comments on
whether a QHP issuer whose plan design
does not fit into the basic AV calculator
logic should be able to obtain an actuar-
ial certification in limited circumstances.
HHS is considering options to permit such
QHP issuers to obtain an actuarial certi-
fication that the plan design fits into the
calculator logic or to obtain an actuarial
certification that adjustments to the AV
calculator-produced value are appropriate.
The HHS actuarial value bulletin also
states that HHS intends to permit ade min-
imisvariation of plus or minus 2 percent
(so that, for example, a bronze plan could
have an actuarial value between 58 and
62 percent). The bulletin also provides
that amounts contributed by an employer
to an HSA or first made available to an em-
ployee under a health reimbursement ar-
rangement (HRA) would be taken into ac-
count by the AV calculator. The intended
method for accounting for these contribu-
tions is discussed further below.
V. ASSUMPTIONS TO BE USED
IN THE MINIMUM VALUE
DETERMINATION
As discussed above, an employer-spon-
sored plan provides minimum value if its
actuarial value is at least 60 percent. For
employer-sponsored plans in the small
group market, minimum value must be
determined using a method that is consis-
tent with the actuarial value rules under
§ 1302(d) of the Affordable Care Act
and HHS guidance provided under that
provision. It is expected that whether an
employer-sponsored self-insured plan or
insuredlargegroupplanprovidesmin-
imum value would be determined in a
manner generally consistent with the rules
proposed by HHS for the calculation of
actuarial value for plans subject to the
actuarial value rules under § 1302(d),
with appropriate modifications that re-
flect differences in the markets and also
account for the fact that employer-spon-
sored self-insured and insured large group
plans are not required to offer EHBs in
each of the 10 categories. Accordingly,
it is expected that the minimum value of
an employer-sponsored self-insured plan
and insured large group plan would be de-
termined in the same manner as actuarial
value under § 1302(b) of the Affordable
Care Act, except that these plans might be
valued using a comparison to claims data
reflecting typical self-insured employer
plans, which would be based on continu-
ance tables
5
published specifically for use
by such plans.
6
Moreover, employer-spon-
sored self-insured and insured large group
plans, as noted above, are neither required
to cover each of the categories of EHBs
nor to conform their plans to any of the
EHB benchmarks that HHS intends to
apply to QHPs, but would be permitted
to take into account all benefits provided
by the plan that are included in any of the
EHB benchmarks.
In addition, an employer-sponsored
plan would be permitted to add to the
plan’s value the employer contributions
to an HSA and amounts made available
under an HRA using a method similar to
the method used by QHPs that are offered
through a SHOP Exchange, as defined in
§ 1311(b)(1)(B) of the Affordable Care
Act.
A. Standard Population and Utilization
Section 1302(d)(2)(A) of the Afford-
able Care Act specifies that actuarial
value is computed based on the health
expenses that are expected to be incurred
by a standard population, rather than the
population that a plan actually covers. For
purposes of determining minimum value
in a manner that meets this standard, it
is expected that two types of continuance
tables would be made available for use
by employer-sponsored plans. First, as
described in the AV bulletin, HHS intends
to publish continuance tables based on
claims representing the entire range of
EHB benchmark benefits and population
data for employer-sponsored and individ-
ual market plans, with permissible state
or regional adjustments to the standard
population, utilization and pricing. These
continuance tables would be incorporated
into the AV calculator and would be used
by QHPs and employer-sponsored plans in
the small group market. Second, to reflect
the differences between the population
covered by QHPs (and plans in the small
group market) and the population covered
by employer-sponsored self-insured and
insured large group plans, HHS intends
to publish continuance tables based on
claims and population data for typical
self-insured employer-sponsored plans.
This second set of continuance tables
would be incorporated into an MV calcu-
lator, which would be provided and could
be used to calculate the actuarial value of
an employer-sponsored self-insured plan
or an insured large group plan. This set
of continuance tables would not include
claims or population data for plans that are
required under the law to provide EHBs or
to meet state benefit mandates.
B. Treatment of HSAs and HRAs in
Calculating Minimum Value
As noted above, the HHS actuarial
value bulletin provides a potential ap-
proach to the calculation of actuarial value
for a high deductible health plan (HDHP)
that is linked to an HSA, as defined in
§ 223, or a group health plan that is inte-
grated with an HRA described in Notice
2002–45, 2002–2 C.B. 93, and Rev. Rul.
2002–41, 2002–2 C.B. 75.
The HHS actuarial value bulletin says
that HHS intends to propose that, in cal-
culating the actuarial value of the com-
bined HDHP and HSA or combined em-
ployer-sponsored plan and HRA, the cal-
culation would assume that the employer
contribution to the HSA or amount first
made available under an HRA is used by
the employee to pay for cost-sharing. Ac-
cordingly, an appropriate portion of these
amounts would be credited to the numera-
tor of the actuarial value calculation. This
5
A health insurance continuance table is a distribution of annual paid claims arranged in a format that shows the amount of claims paid at each increasing level of expenditure, adding up to
the total amount of expenditures for a covered group of enrollees.
6
This use of claims data reflected in the continuance tables would be relevantonly for the purpose of determining minimum value, and does not imply thata plan must provide a particular
set of benefits.
2012–20 I.R.B.908May 14, 2012

means that any current year HSA contri-
butions and amounts first made available
under an HRA could be used to determine
the actuarial value of an employer-spon-
sored plan. Generally, the employer would
receive the same credit for HSA contri-
butions in the numerator of the actuar-
ial value calculation as it would receive
for the same amount of first-dollar insur-
ance coverage. The same rule would apply
for amounts first made available under an
HRA. (See HHS actuarial value bulletin,
“Treatment of Health Savings Accounts
and Health Reimbursement Arrangements
in Calculating Actuarial Value.”)
Treasury and the Service intend to fol-
low HHS’s rules for including employer
contributions to an HSA and amounts
made available under an HRA in the value
of an employer-sponsored HDHP com-
bined with an HSA or an employer-spon-
soredplancombinedwithanHRAwhen
calculating the actuarial value of an em-
ployer-sponsored plan for purposes of
determining whether it provides minimum
value.
VI. OPTIONS FOR DETERMINING
MINIMUM VALUE
Under guidance to be issued by Trea-
sury and the Service, and consistent with
rules to be promulgated by HHS, em-
ployer-sponsored plans would be able to
use any one of several tests to determine
whether the plan meets minimum value.
Comments are requested on three potential
approaches described below.
A. AV and MV Calculators
Under this option, employer-sponsored
plans would be able to determine their ac-
tuarial value by entering information about
the cost-sharing features of the plan for dif-
ferent categories of benefits into a calcu-
lator. As described in the HHS actuarial
value bulletin (in the section entitled “Op-
erational Method for AV Calculation Us-
ing Standard Data”), HHS intends to pro-
vide an AV calculator that QHPs and plans
in the small group market could use to de-
termine the actuarial value of their plans.
In addition, HHS and Treasury intend to
develop an MV calculator, into which an
employer-sponsored self-insured plan and
insured large group plan would be able to
enter cost sharing information that would
be similar in design to the AV calculator
but based on continuance tables reflect-
ing claims data of typical self-insured em-
ployer plans. As such, the data underly-
ing the MV calculator would represent the
range of benefits covered by self-insured
plans.
A calculator generally would be used
to make minimum value determinations
by employer-sponsored plans that have
standard cost-sharing features. An em-
ployer-sponsored plan would be able to
input a limited set of information on the
benefits offered under the plan and spec-
ified cost-sharing features (for example,
deductibles, co-insurance, and maximum
out-of-pocket costs) for the four core cate-
gories of benefits: physician and mid-level
practitioner care, hospital and emergency
room services, pharmacy benefits, and
laboratory and imaging services. The cal-
culator would also take into consideration
the annual employer contributions to an
HSA or amounts made available under an
HRA, if applicable.
B. Design-Based Safe Harbor Checklists
Based on analysis and information pro-
vided by HHS, Treasury and the Service
intend to issue guidance that would give
certain employer-sponsored plans an easy
means to determinewhether a plan pro-
vides minimum value without using a cal-
culator or performing any calculations and
without the need for actuarial expertise.
This alternative would provide an array of
safe harbor checkliststhat employer-spon-
sored plans may compare to their plan’s
coverage. If the employer-sponsored
plan’s terms are consistent with or more
generous than any one of the safe harbor
checklists, the plan would be treated as
providing minimum value.
The safe harbor checklists would be
used to make minimum value determina-
tions for plans that cover all of the four
core categories of benefits and services
and have specified cost-sharing amounts.
Each safe harbor checklist would describe
the cost-sharing attributes of a plan (such
as deductibles, co-pays, co-insurance and
maximum out of pocket costs) that apply to
the four core categories of benefits and ser-
vices.
7
The guidance would provide sev-
eral safe harbor options, including cover-
age equivalent to an HDHP combined with
an employer-funded HSA, that would sat-
isfy the MV requirement. An employer-
sponsored plan providing the four core cat-
egories would be treated as providing min-
imum value if its cost-sharing attributes
are at least as generous as any one of the
safe harbor checklist options.
Treasury and the Service expect to re-
lease the safe harbor checklists when HHS
and Treasury release the MV calculator.
C. Actuarial Certification
Neither a calculator nor the safe harbor
checklists would be able to accommodate
employer-sponsored plans with “nonstan-
dard” features, such as quantitative limits
on any of the four core categories of ben-
efits (including, for example, a limit on
the number of physician visits or covered
days in the hospital). Under a third op-
tion, consistent with the options proposed
in the HHS actuarial value bulletin, em-
ployer-sponsored plans with nonstandard
features would be able to generate an ini-
tial value using a calculator and then en-
gage a certified actuary to make appropri-
ate adjustments that take into considera-
tion the nonstandard features.
Employer-sponsored plans with non-
standard features of a certain type and
magnitude would also have the option of
engaging a certified actuary to determine
the plan’s actuarial value without the use
of a calculator. The actuarial value would
be determined in such case in accordance
with the Actuarial Standards of Practice
established by the Actuarial Standards
Board. The certified actuary would make
this determination based on the plan’s ben-
efits and coverage data and the standard
population, utilization and pricing tables
published by HHS in consultation with
Treasury in the form of the continuance
tables available for purposes of the val-
uation of employer-sponsored plans and
consistent with applicable administrative
guidance.
VII. REQUEST FOR COMMENTS
Comments are requested on issues to
be addressed in guidance on determining
7
Although employer-sponsored plans are not required to cover all four categories of coverage, it is anticipated that plans failing to cover these categories would not satisfy any of the design-
based safe harbors.
May 14, 20129092012–20 I.R.B.

minimum value for an employer-spon-
sored plan. Comments are requested on
issues plan sponsors, issuers, and employ-
ers may face in evaluating plan designs
that will cover part or all of 2014, includ-
ing suggestions for transitional relief for
plan years that start before and end in
2014.
Comments are requested on the poten-
tial alternative methods for determining
whether an employer-sponsored plan pro-
vides minimum value. Comments are
specifically requested on the following
points:
1. The AV calculator or MV calculator
would permit sponsors and issuers of
employer-sponsored plans to enter in-
formation reflecting the benefits they
cover and the cost-sharing features re-
lating to the four core categories of
benefits. Comments are requested on
whether and how the actuarial value
initially generated by the AV calcula-
torortheMVcalculatorcouldbead-
justed to take into consideration other
benefits provided under the plan. For
example, how could benefits such as
wellness benefits be added to the ac-
tuarial value initially generated by the
AV calculator or the MV calculator to
determine whether an employer-spon-
sored plan provides minimum value?
Are there other examples of benefits
that employer-sponsored plans cover
today or are likely to cover that might
not be captured by the MV calcula-
tor and, if so, are employer-sponsored
plans that cover those benefits typi-
cally near 60 percent actuarial value
or more likely to be well above 60 per-
cent actuarial value?
2. As discussed above, employer-spon-
sored plans with nonstandard features,
such as quantitative limits on the four
core categories of benefits, would not
be able to use the AV calculator or
the MV calculator (without an adjust-
ment) to determine whether the plan
provides minimum value. Comments
are requested on nonstandard features
within the four core categories that are
sufficiently narrow that the AV calcu-
lator or the MV calculator could still
be used without adjustment to deter-
mine whether a plan provides min-
imum value and on the quantitative
limits that employer-sponsored plans
commonly use today. Comments are
also requested on other plan features
that could require the plan to adjust the
valuation generated by the AV calcu-
lator or MV calculator.
3. Comments are requested on the terms
that should be included in the safe
harbor checklists and the types of
plans for which safe harbor checklists
should be developed.
4. With respect to a possible independent
actuarial value certification, com-
ments are requested on standards and
safeguards that should be applied to
ensure that the plan meets the 60 per-
cent actuarial value threshold for the
minimum value determination.
Comments may be submitted in writ-
ing on or before June 11, 2012. Com-
ments should be submitted to Internal
Revenue Service, CC:PA:LPD:PR (No-
tice 2012–31), Room 5203, P.O. Box
7604, Ben Franklin Station, Washing-
ton, DC 20044, or electronically to
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2012–31” in
the subject line of any electronic
communications.Alternatively,
comments may be hand delivered
between the hours of 8:00 a.m. and
4:00 p.m.Monday to Friday to
CC:PA:LPD:PR (Notice 2012–31),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue NW,
Washington, D.C. All comments will
be available for public inspection and
copying.
FOR ADDITIONAL INFORMATION
For further information on this notice,
call the Office of the Division Counsel/As-
sociate Chief Counsel (Tax Exempt &
Government Entities) at (202) 927–9639
(not a toll-free call).
Request for Comments on
Reporting of Health Insurance
Coverage
Notice 2012–32
I. PURPOSE
This notice invites comments con-
cerning the reporting requirements under
§ 6055 of the Internal Revenue Code
for health insurance issuers, government
agencies, employers that sponsor self-in-
sured plans, and other persons that provide
minimum essential coverage to an individ-
ual. Section 6055 was added by § 1502(a)
of the Patient Protection and Affordable
Care Act, Public Law 111–148, which was
amended by the Health Care and Educa-
tion Reconciliation Act of 2010, Public
Law 111–152 (collectively, the Affordable
Care Act). The reporting requirements
applytocoverageprovidedonorafterJan-
uary 1, 2014. The first information returns
will be filed in 2015. The Department
of the Treasury and the Internal Revenue
Service plan to propose regulations im-
plementing the reporting requirements
under § 6055. The proposed regulations
are expected to include guidance intended
to minimize administrative burden and
duplicative reporting. To assist in the de-
velopment of the proposed regulations,
this notice invites comments on issues
arising under § 6055.
II. BACKGROUND
“Minimum essential coverage” is a
term defined to include health insur-
ance coverage offered in the individual
market (such as a qualified health plan
enrolled in through an Affordable Insur-
ance Exchange (Exchange)), an eligible
employer-sponsored plan, or govern-
ment-sponsored coverage such as Medi-
care, Medicaid, the Children’s Health
Insurance Program, TRICARE, or veter-
ans’ health care under chapter 17 or 18
of Title 38 U.S.C. Section 5000A(f). Un-
der § 5000A(f)(1)(E), the Department of
Health and Human Services, in coordina-
tion with the Treasury Department, may
designate other health benefits coverage
as minimum essential coverage.
Section 6055(a) requires every health
insurance issuer, sponsor of a self-insured
health plan, government agency that ad-
ministers government-sponsored health
insurance programs and other entity that
provides minimum essential coverage to
file annual returns reporting information
for each individual for whom minimum
essential coverage is provided. If health
insurance coverage is provided by a health
insurance issuer and consists of coverage
provided through a group health plan of
an employer, it is anticipated that the reg-
2012–20 I.R.B.910May 14, 2012

ulations would make the health insurance
issuer responsible for the reporting.
Section 6055(b)(1) provides that all
information returns reporting minimum
essential coverage are to contain (1) the
name, address, and taxpayer identification
number of the primary insured and each
other individual covered under the policy
or plan, (2) the dates each individual was
covered under minimum essential cover-
age during the calendar year, (3) in the
case of health insurance coverage, whether
the coverage is a qualified health plan
offered through an Exchange, (4) if the
coverage is a qualified health plan offered
through an Exchange, the amount (if any)
of any advance payment of the premium
tax credit under § 1412 of the Affordable
Care Act or of any cost-sharing reduction
under § 1402 of the Affordable Care Act
for each covered individual, and (5) other
information that the Secretary requires.
Section 6055(b)(2) provides that infor-
mation returns for minimum essential cov-
erage provided by a health insurance is-
suer through an employer’s group health
plan also include the name, address, and
employer identification number of the em-
ployer maintaining the plan, the portion of
the premium to be paid by the employer,
and any other information that the Secre-
tary may require for administering the tax
credit under § 45R (credit for employee
health insurance expenses of small em-
ployers).
Section 6055(c)(1) directs the entity fil-
inganinformationreturnreportingmini-
mum essential coverage to furnish a writ-
ten statement to each individual listed on
the return that shows the information that
must be reported to the Service for that in-
dividual.
In addition, effective for years begin-
ning after 2013, § 6056 directs every ap-
plicable large employer (within the mean-
ing of § 4980H(c)(2)) that is required to
meet the shared employer responsibility
requirements of § 4980H during a calendar
year to file a return with the Service that re-
ports the terms and conditions of the health
care coverage provided to the employer’s
full-time employees for the year. The re-
turn also is required to include informa-
tion on the employer’s full-time employ-
ees, including those who received the cov-
erage and when they received it. Section
6056(d) permits the Secretary to provide,
to the maximum extent feasible, that any
return or statement required under § 6056
may be provided as part of a return or state-
ment under § 6055 or § 6051 (relating to
reporting by employers on the Form W–2,
Wage and Tax Statement),andthatanap-
plicable large employer offering coverage
of an issuer may agree with the issuer to
include information under § 6056 with the
return and statement provided by the is-
suer under § 6055. See Notice 2012–33,
2012–20 I.R.B. 912 (May 14, 2012).
III. REQUEST FOR COMMENTS
The Treasury Department and the Ser-
vice request comments on issues that
should be addressed in regulations imple-
menting reporting under § 6055, including
but not limited to:
1. How to determine when an individ-
ual’s coverage begins and ends for
purposes of reporting the dates of cov-
erage.
2. How to minimize duplication between
the reporting by health insurance is-
suers and employers under § 6055
and the reporting by Exchanges under
§ 36B(f)(3).
3. How to coordinate and minimize du-
plication between the reporting under
§ 6055, § 6056, and any other ap-
plicable Code provision for employ-
ers that sponsor self-insured plans, in-
cluding but not limited to the poten-
tial combined reporting referred to in
§ 6056(d), as described above.
4. When minimum essential coverage is
provided through a voluntary employ-
ees’ beneficiary association or other
type of welfare benefit fund, who is
required to report under § 6055 and
what, if any, special rules should ap-
ply.
5. Whether there are any specific con-
cerns that should be taken into account
in any of the following circumstances:
a. In the case of electronic infor-
mation reporting and delivery of
statements to individuals and the
Service;
b. If a third party administrator has
information that is relevant to re-
porting for a self-insured plan;
c. If an individual is covered under
one type of coverage for part of
the year and another type of cov-
erage for another part of the year;
or
d. When minimum essential cover-
age is provided under a multiem-
ployer plan.
6. Whether any difficulties exist in iden-
tifying the person responsible for ad-
ministering information reporting for
governmental coverage, for example
in state-administered programs such
as Medicaid.
7. Any additional suggestions for mini-
mizing burden on entities reporting in-
formation under § 6055.
Comments may be submitted in writ-
ing on or before June 11, 2012. Com-
ments should be submitted to Internal
Revenue Service, CC:PA:LPD:PR (No-
tice 2012–32), Room 5203, P.O. Box
7604, Ben Franklin Station, Washing-
ton, DC 20044, or electronically to
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2012–32” in
the subject line of any electronic
communications.Alternatively,
comments may be hand delivered
between the hours of 8:00 a.m. and
4:00 p.m.Monday to Friday to
CC:PA:LPD:PR (Notice 2012–32),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue NW,
Washington, D.C. All comments will
be available for public inspection and
copying.
IV. DRAFTING INFORMATION
The principal authors of this notice are
Andrew Braden and Frank W. Dunham III
of the Office of Associate Chief Counsel
(Income Tax & Accounting). For further
information, please contact Mr. Braden
or Mr. Dunham at (202) 622–4960 (not a
toll-free call).
May 14, 20129112012–20 I.R.B.

Request for Comments on
Reporting by Applicable
Large Employers on Health
Insurance Coverage Under
Employer-Sponsored Plans
Notice 2012–33
I. PURPOSE
This notice invites comments on report-
ing under § 6056 of the Internal Revenue
Code for applicable large employers (as
defined in § 4980H(c)(2)) that are sub-
ject to § 4980H. Section 6056 was enacted
by § 1514(a) of the Patient Protection and
Affordable Care Act, Pub. L. 111–148
(enacted on March 23, 2010), which was
amended by the Health Care and Educa-
tion Reconciliation Act, Pub. L. 111–152
(enacted on March 30,2010) (collectively,
the Affordable Care Act). Section 6056
requires reporting of certain information
on employer-provided health care cover-
age provided on or after January 1, 2014
and the furnishing of related statements to
employees. The first information returns
will be filed in 2015. The Internal Rev-
enue Service will use the information that
employers report under § 6056 to verify
employer-sponsored coverage and to ad-
minister the shared employer responsibil-
ity provisions under § 4980H(a) and (b).
See generally Notice 2011–36, 2011–21
I.R.B. 792, and Notice 2011–73, 2011–40
I.R.B. 74.
The Department of the Treasury and
the Service intend to propose regulations
implementing the reporting requirements
of § 6056. The proposed regulations are
expected to include guidance intended to
minimize administrative burden and du-
plicative reporting. To assist in the devel-
opment of the proposed regulations, this
notice invites comments on issues aris-
ing under § 6056, including on possible
approaches for coordinating and minimiz-
ing duplication between the information
required to be reported and furnished by
employers under § 6056 and information
required to be reported and/or furnished
by employers or other persons under other
applicable Code provisions. For exam-
ple, § 6056(d) permits the Secretary of
the Treasury to provide, to the maximum
extent feasible, that any return or state-
ment required under § 6056 may be pro-
vided as part of a return or statement un-
der § 6055 (relating to reporting by entities
that provide minimum essential coverage)
or § 6051 (relating to reporting by employ-
ers on the Form W–2,Wage and Tax State-
ment), and that an applicable large em-
ployer offering coverage of an issuer may
agree with the issuer to include informa-
tion under § 6056 with the return and state-
ment required to be provided by the issuer
under § 6055.
II. BACKGROUND
A.ReportingtotheService
Section 6056(a), effective for years be-
ginning after December 31, 2013, directs
every applicable large employer (within
the meaning of § 4980H(c)(2)) that must
meet the shared employer responsibility
requirements of § 4980H during a calen-
dar year to file a return with the Service
that reports the terms and conditions of the
health care coverage provided to the em-
ployer’s full-time employees for the year.
Section 6056(b) generally provides that
thereturnusedtosatisfytherequirements
under § 6056 must:
•Include the name and Employer Identi-
fication Number (EIN) of the applica-
ble large employer;
•Include the date the return is filed;
•Certify whether the applicable large
employer offers its full-time em-
ployees (and their dependents) the
opportunity to enroll in minimum
essential coverage under an eligible
employer-sponsored plan (as defined
in § 5000A(f)(2)) and, if so, certify
1. The duration of any waiting period
(as defined in § 6056(b)(2)(C))
with respect to such coverage;
2. The months during the calendar
year when coverage under the plan
was available;
3. The monthly premium for the low-
est cost option in each enrollment
category under the plan; and
4. The employer’s share of the total
allowed costs of benefits provided
under the plan.
•Report the number of full-time em-
ployees for each month of the calendar
year;
•Report, for each full-time employee,
the name, address, and taxpayer identi-
fication number (TIN) of the employee
and the months (if any) during which
the full-time employee (or any depen-
dents) were covered under the eligible
employer-sponsored plan; and
•Include such other information as may
be required by the Secretary of the
Treasury.
B. Reporting to Employees
Section 6056(c) provides that, no later
than January 31 following the calendar
year referred to in § 6056(a) and (b), the
applicable large employer will furnish to
each full-time employee whose informa-
tion is required to be reported to the Ser-
vice under § 6056(b) a written statement
that includes:
•The applicable large employer’s name
and address;
•The applicable large employer’s con-
tact information (including a contact
phone number);
•The information relating to coverage
provided to that employee (and depen-
dents) that is required to be reported on
the § 6056 return.
Section 6056(e) generally permits gov-
ernmental units or any agency or instru-
mentality thereof to designate a person to
comply with the § 6056 reporting on behalf
of the governmental unit, agency or instru-
mentality.
III. REQUEST FOR COMMENTS
Treasury and the Service anticipate
proposing regulations under § 6056, and
this notice requests comments on issues
arising under § 6056 that would be helpful
for the regulations to address, including
how to coordinate and minimize dupli-
cation between the data employers must
report under § 6056 and the data they must
report under § 6055 (which provides for
annual reporting by employers that spon-
sor self-insured plans) or other applicable
Code or Affordable Care Act provisions.
See Notice 2012–32, 2012–20 I.R.B. 910
(May 14, 2012).
Comments must be submitted by
June 11, 2012. Comments should be
submitted to Internal Revenue Service,
CC:PA:LPD:RU (Notice 2012–33), Room
2012–20 I.R.B.912May 14, 2012

5203, PO Box 7604, Ben Franklin Sta-
tion, Washington, DC 20224. Submis-
sions may also be hand-delivered Monday
through Friday between the hours of 8 a.m.
and 4 p.m. to the Courier’s Desk, 1111
Constitution Avenue, NW, Washington,
DC 20224, Attn: CC:PA:LPD:RU (Notice
2012–33), Room 5203. Submissions
may also be sent electronically via the
internet to the following e-mail address:
Notice.Comments@irscounsel.treas.gov.
Include the notice number (Notice
2012–33) in the subject line.
IV. DRAFTING INFORMATION
The principal author of this no-
tice is R. Lisa Mojiri-Azad of the
Office of Division Counsel/Associate
Chief Counsel (Tax Exempt and
Government Entities), though other
Treasury Department and Service officials
participated in its development. For
further information on all other provisions
of this notice, contact R. Lisa Mojiri-Azad
at (202) 622–6080 (not a toll-free number).
26 CFR 1.6049.00–00: Returns relating to payments
of interest.
(Also: 1.3406.07–00: Exceptions to backup with-
holding.)
Implementation of
Nonresident Alien Deposit
Interest Regulations
Rev. Proc. 2012–24
SECTION 1. PURPOSE
Sections 1.6049–4(b)(5) and 1.6049–8
of the Income Tax Regulations, as revised
by T.D. 9584, require the reporting of cer-
tain deposit interest paid to nonresident
alien individuals on or after January 1,
2013. The purpose of this revenue pro-
cedure is to list, in Section 3, the coun-
tries with which the United States has in
effect an income tax or other convention
or bilateral agreement relating to the ex-
change of information within the meaning
of section 6103(k)(4) pursuant to which
the United States agrees to provide, as well
as receive, information and under which
the competent authority is the Secretary
of the Treasury or his delegate, as de-
scribed in §1.6049–8(a). As discussed in
the preamble to the regulations, even when
such an agreement exists, the Internal Rev-
enue Service (IRS) is not compelled to ex-
change information, including information
collected pursuant tothe regulations, if
there is concern regarding the use of the in-
formation or other factors exist that would
make exchange inappropriate. This rev-
enue procedure also identifies in Section 4
the countries with which the Treasury De-
partment and the IRS have determined that
it is appropriate to have an automatic ex-
change relationship with respect to the in-
formation collected under the regulations.
This revenue procedure will be updated as
appropriate.
SECTION 2. BACKGROUND
The regulations provide that in the case
of reportable interest aggregating $10 or
more paid to a nonresident alien individ-
ual (as defined in section 7701(b)(1)(B)
of the Internal Revenue Code), the payor
shall make an information return on Form
1042–S for the calendar year in which the
interest is paid. Reportable interest is inter-
est described in section 871(i)(2)(A) that
relatestoadepositmaintainedatanoffice
within the United States, and that is paid to
a nonresident alien individual who is a res-
ident of a country identified, in an applica-
ble revenue procedure (see §601.601(d)(2)
of this chapter) as of December 31 prior
to the calendar year in which the inter-
est is paid, as a country with which the
United States has in effect an income tax
or other convention or bilateral agreement
relating to the exchange of information
within the meaning of section 6103(k)(4)
pursuant to which United States agrees to
provide, as well as receive, information
and under which thecompetent author-
ity is the Secretary of the Treasury or his
delegate. This revenue procedure consti-
tutes the revenue procedure referenced in
§1.6049–8(a) and will be updated by sub-
sequent revenue procedures as appropri-
ate.
SECTION 3. COUNTRIES OF
RESIDENCE WITH RESPECT
TO WHICH THE REPORTING
REQUIREMENT APPLIES
The following are countries with which
the United States has in effect an income
tax or other convention or bilateral agree-
ment relating to the exchange of tax in-
formation within the meaning of section
6103(k)(4) pursuant to which the United
States agrees to provide, as well as receive,
information and under which the compe-
tent authority is the Secretary of the Trea-
sury or his delegate:
Antigua & Barbuda
Aruba
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belgium
Bermuda
British Virgin Islands
Bulgaria
Canada
China
Costa Rica
Cyprus
Czech Republic
Denmark
Dominica
Dominican Republic
Egypt
Estonia
Finland
France
Germany
Gibraltar
Greece
Grenada
Guernsey
Guyana
Honduras
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Jamaica
Japan
Jersey
Kazakhstan
Korea (South)
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Marshall Islands
Mexico
Monaco
Morocco
Netherlands
May 14, 20129132012–20 I.R.B.

Netherlands island territories: Bonaire,
Curacao, Saba, St. Eustatius and
St. Maarten (Dutch part)
New Zealand
Norway
Pakistan
Panama
Peru
Philippines
Poland
Portugal
Romania
Russian Fed
eration
Slovak Rep.
Slovenia
South Afri
ca
Spain
Sri Lanka
Sweden
Switzerland
Thailand
Trinidad
and Tobago
Tunisia
Turkey
Ukraine
United Kingdom
Venezuela
SECTION 4. COUNTRIES WITH
WHICH TREASURY AND THE
IRS HAVE DETERMINED THAT
AUTOMATIC EXCHANGE OF
DEPOSIT INTEREST INFORMATION
IS APPROPRIATE
The following list identifies the
countries with which the automatic ex-
change of the information collected under
§§1.6049–4(b)(5) and 1.6049–8 has been
determined by the Treasury Department
andtheIRStobeappropriate:
Canada
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective for
interest paid on or after January 1, 2013.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kathryn T. Holman of the
Office of Chief Counsel International
(International). For further information
regarding this revenue procedure, contact
Kathryn T. Holman at (202) 622–3840
(not a toll-free call).
26 CFR 601.201: Rulings and determination letters.
(Also: Part I, §§ 25, 103, 143.)
Rev. Proc. 2012–25
SECTION 1. PURPOSE
This revenue procedure provides is-
suers of qualified mortgage bonds, as
defined in section 143(a) of the Internal
Revenue Code, and issuers of mortgage
credit certificates, as defined in section
25(c), with (1) the nationwide average
purchase price for residences located in
the United States, and (2) average area
purchase price safe harbors for residences
located in statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, except
as provided in section 103(b), gross in-
come does not include interest on any state
or local bond. Section 103(b)(1) provides
that section 103(a) shall not apply to any
private activity bond that is not a “qualified
bond” within the meaning of section 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activitybondifsuchbond(1)isaquali-
fied mortgage bond under section 143, (2)
meets the volume cap requirements under
section 146, and (3) meets the applicable
requirements under section 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A) pro-
vides that the term “qualified mortgage is-
sue” means an issue of one or more bonds
by a state or political subdivision thereof,
but only if: (i) all proceeds of the issue (ex-
clusive of issuance costs and a reasonably
required reserve) are to be used to finance
owner-occupied residences; (ii) the issue
meets the requirements of subsections (c),
(d), (e), (f), (g), (h), (i), and (m)(7) of sec-
tion 143; (iii) the issue does not meet the
private business tests of paragraphs (1) and
(2) of section 141(b); and (iv) with respect
to amounts received more than 10 years
after the date of issuance, repayments of
$250,000 or more of principal on mortgage
financing provided by the issue are used by
the close of the first semiannual period be-
ginning after the date the prepayment (or
complete repayment) is received to redeem
bonds that are part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of section 143(e) if the ac-
quisition cost of each residence financed
by the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro-
vides that, in the case of a targeted area res-
idence (as defined insection 143(j)), sec-
tion 143(e)(1) shall be applied by substi-
tuting 110 percent for 90 percent.
.04 Section 143(e)(2) provides that the
term “average area purchase price” means,
with respect to any residence, the average
purchase price of single-family residences
(in the statistical area in which the resi-
dence is located) that were purchased dur-
ing the most recent 12-month period for
which sufficient statistical information is
available. Under sections 143(e)(3) and
(4), respectively, separate determinations
aretobemadefornewandexistingresi-
dences, and for two-, three-, and four-fam-
ily residences.
.05 Section 143(e)(2) provides that the
determination of the average area purchase
price for a statistical area shall be made as
ofthedateonwhichthecommitmentto
provide the financing is made or, if earlier,
the date of the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a
metropolitan statistical area (MSA), and
(ii) any county (or the portion thereof)
that is not within an MSA. Section
143(k)(2)(C) further provides that if suf-
ficient recent statistical information with
respect to a county (or portion thereof)
is unavailable, the Secretary may sub-
stitute another area for which there is
sufficient recent statistical information for
such county (or portion thereof). In the
case of any portion of a State which is
not within a county, section 143(k)(2)(D)
provides that the Secretary may designate
as a county any area that is the equivalent
of a county. Section 6a.103A–1(b)(4)(i)
of the Temporary Income Tax Regulations
(issued under section 103A of the Internal
Revenue Code of 1954, the predecessor of
section 143) provides that the term “State”
2012–20 I.R.B.914May 14, 2012

includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A–2(f)(5)(i) pro-
vides that an issuer may rely upon the aver-
age area purchase price safe harbors pub-
lished by the Department of the Treasury
for the statistical area in which a residence
is located. Section 6a.103A–2(f)(5)(i)
further provides that an issuer may use
an average area purchase price limitation
different from the published safe harbor if
the issuer has more accurate and compre-
hensive data for the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a state or
political subdivision to establish a quali-
fied mortgage credit certificate program.
In general, a qualified mortgage credit
certificate program is a program under
which the issuing authority elects not to
issue an amount of private activity bonds
that it may otherwise issue during the
calendar year under section 146, and in
their place, issues mortgage credit certifi-
cates to taxpayers in connection with the
acquisition of their principal residences.
Section 25(a)(1) provides, in general, that
theholderofamortgage credit certificate
may claim a federal income tax credit
equal to the product of the credit rate
specified in the certificate and the interest
paid or accrued during the tax year on the
remaining principal of the indebtedness
incurred to acquire the residence. Section
25(c)(2)(A)(iii)(III) generally provides
that residences acquired in connection
with the issuance of mortgage credit cer-
tificates must meet the purchase price
requirements of section 143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, section
25(c)(2)(A)(iii)(IV)provides that holders
of mortgage credit certificates must meet
the income requirement of section 143(f).
Generally, under sections 143(f)(1) and
25(c)(2)(A)(iii)(IV), the income require-
ment is met only if all owner-financing
under a qualified mortgage bond and all
mortgage credit certificates issued under a
qualified mortgage credit certificate pro-
gram are provided to mortgagors whose
family income is 115 percent or less of the
applicable median family income. Section
143(f)(5), however, generally provides
for an upward adjustment to the percent-
age limitation in high housing cost areas.
High housing cost areas are defined in
section 143(f)(5)(C) as any statistical area
for which the housing cost/income ratio is
greater than 1.2.
.10 Under section 143(f)(5)(D), the
housing cost/income ratio with respect to
any statistical area is determined by divid-
ing (a) the applicable housing price ratio
for such area by (b) the ratio that the area
median gross income for such area bears
to the median gross income for the United
States. The applicablehousing price ratio
is the new housing price ratio (new hous-
ing average area purchase price divided by
the new housing average purchase price
for the United States) or the existing hous-
ing price ratio (existing housing average
area purchase price divided by the existing
housing average purchase price for the
United States), whichever results in the
housing cost/income ratio being closer to
1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of Co-
lumbia, Puerto Rico, the Northern Mari-
ana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2011–23, 2011–15 I.R.B. 626.
.12 The nationwide average purchase
price limitation was last published in
section 4.02 of Rev. Proc. 2011–23.
Guidance with respect to the United States
and area median grossincome figures that
are to be used in computing the housing
cost/income ratio described in section
143(f)(5) was last published in Rev. Proc.
2012–16, 2012–10 I.R.B. 452.
.13 This revenue procedure uses FHA
loan limits for a given statistical area to
calculate the average area purchase price
safe harbor for that area. FHA sets lim-
its on the dollar value of loans it will in-
sure based on median home prices and
conforming loan limits established by the
Federal Home Loan Mortgage Corpora-
tion. In particular, FHA sets an area’s loan
limit at 95 percent of the median home
sales price for the area, subject to certain
floors and caps measured against conform-
ing loan limits.
.14 To calculate the average area pur-
chase price safe harbors in this revenue
procedure, the FHA loan limits are ad-
justed to take into account the differences
between average and median purchase
prices. Because FHA loan limits do not
differentiate between new and existing
residences, this revenue procedure con-
tains a single average area purchase price
safe harbor for both new and existing
residences in a statistical area. The Trea-
sury Department and the Internal Revenue
Service have determined that FHA loan
limits provide a reasonable basis for de-
termining average area purchase price
safe harbors. If the Treasury Department
and the Internal Revenue Service become
aware of other sources of average purchase
price data, including data that differentiate
between new and existing residences, con-
sideration will be given as to whether such
data provide a more accurate method for
calculating average area purchase price
safe harbors.
.15 The average area purchase price
safeharborslistedinsection4.01ofthis
revenue procedure are based on FHA loan
limits released December 02, 2011. FHA
loan limits are available for statistical ar-
eas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands,
American Samoa, the Virgin Islands, and
Guam. See section 3.03 of this revenue
procedure with respect to FHA loan lim-
its revised after December 02, 2011.
.16 OMB Bulletin No. 03–04, dated
and effective June 6, 2003, revised the def-
initions of the nation’s metropolitan areas
and recognized 49 new metropolitan sta-
tistical areas. The OMB bulletin no longer
includes primary metropolitan statistical
areas.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
May 14, 20129152012–20 I.R.B.

procedure. Average area purchase price
safe harbors are provided for single-family
and two to four-family residences. For
each type of residence, section 4.01 of this
revenue procedure contains a single safe
harbor that may be used for both new and
existing residences. Issuers of qualified
mortgage bonds and issuers of mortgage
credit certificates may rely on these safe
harbors to satisfy the requirements of sec-
tions 143(e) and (f). Section 4.01 of this
revenue procedure provides safe harbors
for MSAs and for certain counties and
county equivalents. If no purchase price
safe harbor is available for a statistical
area, the safe harbor for “ALL OTHER
AREAS” may be used for that statistical
area.
.02IfaresidenceisinanMSA,thesafe
harbor applicable to it is the limitation of
that MSA. If an MSA falls in more than
one state, the MSA is listed in section 4.01
of this revenue procedure under each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Decem-
ber 02, 2011, an issuer of qualified mort-
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for that
statistical area to compute (as provided in
the next sentence) a revised average area
purchase price safe harbor for the statisti-
cal area provided that the issuer maintains
records evidencing the revised FHA loan
limit. The revised average area purchase
price safe harbor for that statistical area
is computed by dividing the revised FHA
loan limit by .975.
.04 If, pursuant to section
6a.103A–2(f)(5)(i), an issuer uses more
accurate and comprehensive data to
determine the average area purchase price
for a statistical area, the issuer must make
separate average area purchase price
determinations for new and existing resi-
dences. Moreover, when computing the
average area purchase price for a statistical
area that is an MSA, as defined in OMB
Bulletin No. 03–04, the issuer must make
the computation for the entire applicable
MSA. When computing the average area
purchase price for a statistical area that
is not an MSA, the issuer must make the
computation for the entire statistical area
and may not combine statistical areas.
Thus, for example, the issuer may not
combine two or more counties.
.05 If an issuer receives a ruling permit-
ting it to rely on an average area purchase
price limitation that is higher than the
applicable safe harbor in this revenue
procedure, the issuer may rely on that
higher limitation for the purpose of satis-
fying the requirements of section 143(e)
and (f) for bonds sold, and mortgage
credit certificates issued, not more than 30
months following the termination date of
the12-monthperiodusedbytheissuerto
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue proce-
dure sets forth a single nationwide average
purchase price for purposes of computing
the housing cost/income ratio under sec-
tion 143(f)(5).
.07 Issuers must use the nationwide av-
erage purchase price set forth in section
4.02 of this revenue procedure when com-
puting the housing cost/income ratio un-
der section 143(f)(5) regardless of whether
they are relying on the average area pur-
chase price safe harbors contained in this
revenue procedure or using more accurate
and comprehensive data to determine av-
erage area purchase prices for new and ex-
isting residences for a statistical area that
are different from the published safe har-
bors in this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2011–23, the is-
suer must use the nationwide average pur-
chase price set forth in section 4.02 of Rev.
Proc. 2011–23 in computing the housing
cost/income ratio under section 143(f)(5).
Likewise, if, pursuant to section 6.05 of
this revenue procedure, an issuer relies
on the nationwide average purchase price
published in Rev. Proc. 2011–23, the is-
suer may not rely on the average area pur-
chase price safe harbors published in this
revenue procedure.
SECTION 4. AVERAGE AREA AND
NATIONWIDE AVERAGE PURCHASE
PRICES
.01 Average area purchase prices for
single-family and two to four-family res-
idences in MSAs, and for certain counties
and county equivalents are set forth below.
The safe harbor for “ALL OTHER AR-
EAS” (found at the end of the table below)
may be used for a statistical area that is not
listed below.
2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
ALEUTIANS WESTAK
$365,641$468,051$565,795$703,128
ANCHORAGEAK
$356,4
10
$456,2
56
$551,5
38
$685,3
85
BRISTOL BAYAK
$300,769$385,026$465,385$578,410
DENALIAK
$324,359$415,231$501,897$623,744
DILLINGHAMAK
$341,026$436,564$527,692$655,795
FAIR
BANKS NORTH
AK
$324,359$415,231$501,897$623,744
JUNEAUAK
$408,974$523,538$632,872$786,513
KETCHIKAN GATEWAK
$33
0,256
$42
2,769
$51
1,026
$63
5,128
KODIAK ISLANDAK
$343,231$439,385$531,128$660,051
MATANUSKA-SUSITAK
$356,410$456,256$551,538$685,385
NOMEAK
$281,897$360,872$436,205$542,103
NO
RTH SLOPE
AK
$314,923$403,128$487,333$605,641
PETERSBURG CENSAK
$297,231$380,513$459,949$571,590
2012–20 I.R.B.916May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
SITKAAK
$442,308$566,205$684,462$850,615
VALDEZ-CORDOVAAK
$278,359$356,359$430,718$535,282
YAKUTAT CITYAK
$398,667$510,359$616,923$766,667
BALDWINAL
$292,308$374,205$452,308$562,103
RUSSELLAL
$297,231$380,513$459,949$571,590
APACHEAZ
$288,462$369,282$446,359$554,718
COCONINOAZ
$461,538$590,821$714,205$887,590
GILAAZ
$333,333$426,718$515,795$641,026
MARICOPAAZ
$355,128$454,615$549,538$682,923
MOHAVEAZ
$330,769$423,436$511,846$636,103
NAVAJOAZ
$316,667$405,385$490,000$608,974
PIMAAZ
$324,359$415,231$501,897$623,744
PINALAZ
$355,128$454,615$549,538$682,923
YAVAPAIAZ
$400,000$512,051$618,974$769,231
ALAMEDACA
$748,462$958,154$1,158,205$1,439,385
ALPINECA
$561,538$718,872$868,923$1,079,897
AMADORCA
$455,128$582,615$704,256$875,231
BUTTECA
$410,256$525,179$634,821$788,974
CALAVERASCA
$474,35
9
$607,23
1
$734,05
1
$912,25
6
COLUSACA
$407,692$521,897$630,872$784,000
CONTRA COSTACA
$748,462$958,154$1,158,205$1,439,385
DEL NORTECA
$319,231$408,667$494,000$613,897
EL DORA
DO
CA
$594,872$761,538$920,513$1,144,000
FRESNOCA
$391,026$500,564$605,077$751,949
GLENNCA
$294
,872
$377
,487
$456
,308
$567
,077
HUMBOLDTCA
$403,846$516,974$624,923$776,615
IMPERIALCA
$333,333$426,718$515,795$641,026
INYOCA
$448,718$574,410$694,359$862,923
KER
N
CA
$378,205$484,154$585,231$727,333
KINGSCA
$333,333$426,718$515,795$641,026
LAKECA
$4
11,538
$5
26,821
$6
36,821
$7
91,436
LASSENCA
$292,308$374,205$452,308$562,103
LOS ANGELESCA
$748,462$958,154$1,158,205$1,439,385
MADERACA
$435,897$558,000$674,513$838,256
M
ARIN
C
A
$748,462$958,154$1,158,205$1,439,385
MARIPOSACA
$423,077$541,590$654,667$813,590
MENDOCINOCA
$525,641$672,923$813,385$1,010,872
MERCEDCA
$484,615$620,410$749,897$931,949
MONOCA
$542,564$694,564$839,590$1,043,385
MONTEREYCA
$748,462$958,154$1,158,205$1,439,385
NAPACA
$748,462$958,154$1,158,205$1,439,385
NEVADACA
$576,923$738,564$892,769$1,109,487
ORANGECA
$748,462$958,154$1,158,205$1,439,385
PLACERCA
$594,872$761,538$920,513$1,144,000
PLUMASCA
$420,513$538,308$650,718$808,667
RIVERSIDECA
$512,821$656,513$793,538$986,205
SACRAMENTOCA
$594,872$761,538$920,513$1,144,000
SAN BENITOCA
$748,462$958,154$1,158,205$1,439,385
SAN BERNARDINOCA
$512,821$656,513$793,538$986,205
May 14, 20129172012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
SAN DIEGOCA
$715,385$915,846$1,107,026$1,375,744
SAN FRANCISCOCA
$748,462$958,154$1,158,205$1,439,385
SAN JOAQUINCA
$501,282$641,744$775,692$964,000
SAN LUIS OBISPOCA
$705,128$902,667$1,091,128$1,356,051
SAN MATEOCA
$748,462$958,154$1,158,205$1,439,385
SANTA BARBARACA
$748,462$958,154$1,158,205$1,439,385
SANTA CLARACA
$748,462$958,154$1,158,205$1,439,385
SANTA CRUZCA
$748,462$958,154$1,158,205$1,439,385
SHASTACA
$434,615$556,359$672,513$835,795
SIERRACA
$312,564$400,103$483,641$601,077
SISKIYOUCA
$301,282$385,692$466,205$579,385
SOLANOCA
$571,795$732,000$884,821$1,099,641
SONOMACA
$679,487$869,846$1,051,487$1,306,718
STANISLAU
S
CA
$434,615$556,359$672,513$835,795
SUTTERCA
$435,897$558,000$674,513$838,256
TEHAMACA
$320,51
3
$410,30
8
$495,94
9
$616,35
9
TULARECA
$333,333$426,718$515,795$641,026
TUOLUMNECA
$448,718$574,410$694,359$862,923
VENTURACA
$748,462$958,154$1,158,205$1,439,385
YOLOCA
$594,872$761,538$920,513$1,144,000
YUBACA
$435,897$558,000$674,513$838,256
ADAMSCO
$416,667$533,385$644,769$801,282
ARAPA
HOE
CO
$416,667$533,385$644,769$801,282
ARCHULETACO
$325,641$416,872$503,897$626,205
BOULDERCO
$471
,795
$603
,949
$730
,051
$907
,282
BROOMFIELDCO
$416,667$533,385$644,769$801,282
CHAFFEECO
$287,179$367,641$444,359$552,256
CLEAR CREEKCO
$416,667$533,385$644,769$801,282
DEN
VER
CO
$416,667$533,385$644,769$801,282
DOUGLASCO
$416,667$533,385$644,769$801,282
EAGLECO
$7
48,462
$9
58,154
$1
,158,205
$1
,439,385
ELBERTCO
$416,667$533,385$644,769$801,282
EL PASOCO
$333,333$426,718$515,795$641,026
GARFIELDCO
$435,897$558,000$674,513$838,256
G
ILPIN
C
O
$416,667$533,385$644,769$801,282
GRANDCO
$365,385$467,744$565,385$702,667
GUNNISONCO
$444,872$569,487$688,410$855,538
HINSDALECO
$571,795$732,000$884,821$1,099,641
JEFFERSONCO
$416,667$533,385$644,769$801,282
LAKECO
$748,462$958,154$1,158,205$1,439,385
LA PLATACO
$455,128$582,615$704,256$875,231
LARIMERCO
$320,513$410,308$495,949$616,359
MESACO
$380,769$487,436$589,231$732,256
MINERALCO
$307,692$393,897$476,103$591,692
OURAYCO
$494,872$633,538$765,795$951,692
PARKCO
$416,667$533,385$644,769$801,282
PITKINCO
$748,462$958,154$1,158,205$1,439,385
ROUTTCO
$692,308$886,256$1,071,333$1,331,385
SAN JUANCO
$435,897$558,000$674,513$838,256
SAN MIGUELCO
$667,949$855,077$1,033,590$1,284,513
2012–20 I.R.B.918May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
SUMMITCO
$748,462$958,154$1,158,205$1,439,385
TELLERCO
$333,333$426,718$515,795$641,026
WELDCO
$428,205$548,154$662,615$823,487
FAIRFIELDCT
$726,923$930,615$1,124,872$1,397,949
HARTFORDCT
$451,282$577,692$698,308$867,846
LITCHFIELDCT
$384,615$492,359$595,179$739,641
MIDDLESEXCT
$451,282$577,692$698,308$867,846
NEW HAVENCT
$397,436$508,769$614,974$764,308
NEW LONDONCT
$408,974$523,538$632,872$786,513
TOLLANDCT
$451,282$577,692$698,308$867,846
WINDHAMCT
$279,487$357,795$432,462$537,487
DISTRICT OF COLDC
$748,462$958,154$1,158,205$1,439,385
KENTDE
$385,897$494,000$597,128$742,103
NEW CASTLEDE
$430,769$551,436$666,564$828,410
SUSSEXDE
$384,615$492,359$595,179$739,641
BAKERFL
$397,436$508,769$614,974$764,308
BAYFL
$406,410$520,256$628,872$781,538
BREVARDFL
$298,718$382,410$462,256$574,462
BROWARDFL
$434,615$556,359$672,513$835,795
CHARLOT
TE
FL
$303,846$388,974$470,154$584,308
CLAYFL
$397,436$508,769$614,974$764,308
COLLIERFL
$544,8
72
$697,5
38
$843,1
28
$1,047
,846
DUVALFL
$397,436$508,769$614,974$764,308
FLAGLERFL
$294,872$377,487$456,308$567,077
FRANKLINFL
$312,821$400,462$484,051$601,590
HERNA
NDO
FL
$300,000$384,051$464,205$576,923
HILLSBOROUGHFL
$300,000$384,051$464,205$576,923
INDIAN RIVERFL
$291
,026
$372
,564
$450
,308
$559
,641
LAKEFL
$362,821$464,462$561,436$697,744
LEEFL
$365,385$467,744$565,385$702,667
MANATEEFL
$453,846$580,974$702,308$872,769
MA
RTIN
FL
$384,615$492,359$595,179$739,641
MIAMI-DADEFL
$434,615$556,359$672,513$835,795
MONROEFL
$
748,462
$
958,154
$
1,158,205
$
1,439,385
NASSAUFL
$397,436$508,769$614,974$764,308
OKALOOSAFL
$320,513$410,308$495,949$616,359
ORANGEFL
$362,821$464,462$561,436$697,744
OSCEOLAFL
$362,821$464,462$561,436$697,744
PALM BEACHFL
$434,615$556,359$672,513$835,795
PASCOFL
$300,000$384,051$464,205$576,923
PINELLASFL
$300,000$384,051$464,205$576,923
ST. JOHNSFL
$397,436$508,769$614,974$764,308
ST. LUCIEFL
$384,615$492,359$595,179$739,641
SARASOTAFL
$453,846$580,974$702,308$872,769
SEMINOLEFL
$362,821$464,462$561,436$697,744
SUMTERFL
$285,897$366,000$442,410$549,795
VOLUSIAFL
$311,538$398,821$482,051$599,128
WALTONFL
$372,092$476,308$575,795$715,538
BARROWGA
$355,128$454,615$549,538$682,923
May 14, 20129192012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
BARTOWGA
$355,128$454,615$549,538$682,923
BRANTLEYGA
$283,333$362,718$438,410$544,872
BUTTSGA
$355,128$454,615$549,538$682,923
CARROLLGA
$355,128$454,615$549,538$682,923
CHATTAHOOCHEEGA
$297,231$380,513$459,949$571,590
CHEROKEEGA
$355,128$454,615$549,538$682,923
CLARKEGA
$306,410$392,256$474,154$589,231
CLAYTONGA
$355,128$454,615$549,538$682,923
COBBGA
$355,128$454,615$549,538$682,923
COWETAGA
$355,128$454,615$549,538$682,923
DAWSONGA
$355,128$454,615$549,538$682,923
DEKALBGA
$355,128$454,615$549,538$682,923
DOUGLASGA
$355,128$454,615$549,538$682,923
FAYETTEGA
$355,128$454,615$549,538$682,923
FORSYTHGA
$355,128$454,615$549,538$682,923
FULTONGA
$355,12
8
$454,61
5
$549,53
8
$682,92
3
GLYNNGA
$283,333$362,718$438,410$544,872
GREENEGA
$679,487$869,846$1,051,487$1,306,718
GWINNETTGA
$355,128$454,615$549,538$682,923
HARALS
ON
GA
$355,128$454,615$549,538$682,923
HARRISGA
$297,231$380,513$459,949$571,590
HEARDGA
$355,
128
$454,
615
$549,
538
$682,
923
HENRYGA
$355,128$454,615$549,538$682,923
JASPERGA
$355,128$454,615$549,538$682,923
LAMARGA
$355,128$454,615$549,538$682,923
MCIN
TOSH
GA
$283,333$362,718$438,410$544,872
MADISONGA
$306,410$392,256$474,154$589,231
MARIONGA
$29
7,231
$38
0,513
$45
9,949
$57
1,590
MERIWETHERGA
$355,128$454,615$549,538$682,923
MUSCOGEEGA
$297,231$380,513$459,949$571,590
NEWTONGA
$355,128$454,615$549,538$682,923
OC
ONEE
GA
$306,410$392,256$474,154$589,231
OGLETHORPEGA
$306,410$392,256$474,154$589,231
PAULDINGGA
$
355,128
$
454,615
$
549,538
$
682,923
PICKENSGA
$355,128$454,615$549,538$682,923
PIKEGA
$355,128$454,615$549,538$682,923
ROCKDALEGA
$355,128$454,615$549,538$682,923
SPALDINGGA
$355,128$454,615$549,538$682,923
WALTONGA
$355,128$454,615$549,538$682,923
HAWAIIHI
$634,615$812,410$982,051$1,220,410
HONOLULUHI
$814,103$1,042,205$1,259,795$1,565,590
KALAWAOHI
$734,615$940,462$1,136,769$1,412,769
KAUAIHI
$793,590$1,015,949$1,228,051$1,526,154
MAUIHI
$810,256$1,037,282$1,253,846$1,558,205
ADAID
$311,538$398,821$482,051$599,128
ADAMSID
$280,769$359,436$434,462$539,949
BLAINEID
$748,462$958,154$1,158,205$1,439,385
BOISEID
$311,538$398,821$482,051$599,128
CANYONID
$311,538$398,821$482,051$599,128
GEMID
$311,538$398,821$482,051$599,128
2012–20 I.R.B.920May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
KOOTENAIID
$293,590$375,846$454,308$564,564
OWYHEEID
$311,538$398,821$482,051$599,128
TETONID
$711,538$910,872$1,101,077$1,368,359
VALLEYID
$474,359$607,231$734,051$912,256
BONDIL
$288,462$369,282$446,359$554,718
BOONEIL
$347,949$445,436$538,410$669,128
CALHOUNIL
$288,462$369,282$446,359$554,718
CLINTONIL
$288,462$369,282$446,359$554,718
COOKIL
$420,513$538,308$650,718$808,667
DEKALBIL
$420,513$538,308$650,718$808,667
DUPAGEIL
$420,513$538,308$650,718$808,667
GRUNDYIL
$420,513$538,308$650,718$808,667
JERSEYIL
$288,462$369,282$446,359$554,718
KANEIL
$420,513$538,308$650,718$808,667
KENDALLIL
$420,513$538,308$650,718$808,667
LAKEIL
$420,513$538,308$650,718$808,667
MCHENRYIL
$420,513$538,308$650,718$808,667
MACOUPINIL
$288,462$369,282$446,359$554,718
MADISONIL
$288,4
62
$369,2
82
$446,3
59
$554,7
18
MONROEIL
$288,462$369,282$446,359$554,718
ST. CLAIRIL
$288,462$369,282$446,359$554,718
WILLIL
$420,513$538,308$650,718$808,667
WINNE
BAGO
IL
$347,949$445,436$538,410$669,128
CLARKIN
$310,256$397,179$480,103$596,667
DEARBORNIN
$346,154$443,128$535,641$665,692
FLOY
D
IN
$310,256$397,179$480,103$596,667
FRANKLININ
$346,154$443,128$535,641$665,692
HARRISONIN
$31
0,256
$39
7,179
$48
0,103
$59
6,667
JASPERIN
$420,513$538,308$650,718$808,667
LAKEIN
$420,513$538,308$650,718$808,667
NEWTONIN
$420,513$538,308$650,718$808,667
OH
IO
IN
$346,154$443,128$535,641$665,692
PORTERIN
$420,513$538,308$650,718$808,667
WASHINGTONIN
$
310,256
$
397,179
$
480,103
$
596,667
B
OONE
K
Y
$346,154$443,128$535,641$665,692
BRACKENKY
$346,154$443,128$535,641$665,692
BULLITTKY
$310,256$397,179$480,103$596,667
CAMPBELLKY
$346,154$443,128$535,641$665,692
GALLATINKY
$346,154$443,128$535,641$665,692
GRANTKY
$346,154$443,128$535,641$665,692
HENRYKY
$310,256$397,179$480,103$596,667
JEFFERSONKY
$310,256$397,179$480,103$596,667
KENTONKY
$346,154$443,128$535,641$665,692
MEADEKY
$310,256$397,179$480,103$596,667
NELSONKY
$310,256$397,179$480,103$596,667
OLDHAMKY
$310,256$397,179$480,103$596,667
PENDLETONKY
$346,154$443,128$535,641$665,692
SHELBYKY
$310,256$397,179$480,103$596,667
SPENCERKY
$310,256$397,179$480,103$596,667
May 14, 20129212012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
TRIMBLEKY
$310,256$397,179$480,103$596,667
ASCENSIONLA
$287,179$367,641$444,359$552,256
EAST BATON ROUGLA
$287,179$367,641$444,359$552,256
EAST FELICIANALA
$287,179$367,641$444,359$552,256
IBERVILLELA
$287,179$367,641$444,359$552,256
JEFFERSONLA
$294,872$377,487$456,308$567,077
LIVINGSTONLA
$287,179$367,641$444,359$552,256
ORLEANSLA
$294,872$377,487$456,308$567,077
PLAQUEMINESLA
$294,872$377,487$456,308$567,077
POINTE COUPEELA
$287,179$367,641$444,359$552,256
ST. BERNARDLA
$294,872$377,487$456,308$567,077
ST. CHARLESLA
$294,872$377,487$456,308$567,077
ST. HELENALA
$287,179$367,641$444,359$552,256
ST. JOHN THE BALA
$294,872$377,487$456,308$567,077
ST. TAMMANYLA
$294,872$377,487$456,308$567,077
WEST BATON ROUGLA
$287,179$367,641$444,359$552,256
WEST FELI
CIANA
LA
$287,179$367,641$444,359$552,256
BARNSTABLEMA
$474,359$607,231$734,051$912,256
BRISTOLMA
$487,179$623,692$753,897$936,872
DUKESMA
$748,462$958,154$1,158,205$1,439,385
ESSEXMA
$537,179$687,692$831,231$1,033,026
FRANKLINMA
$326,
923
$418,
513
$505,
897
$628,
718
HAMPDENMA
$326,923$418,513$505,897$628,718
HAMPSHIREMA
$326,923$418,513$505,897$628,718
MIDDLESEXMA
$537,179$687,692$831,231$1,033,026
NANT
UCKET
MA
$748,462$958,154$1,158,205$1,439,385
NORFOLKMA
$537,179$687,692$831,231$1,033,026
PLYMOUTHMA
$53
7,179
$68
7,692
$83
1,231
$1,
033,026
SUFFOLKMA
$537,179$687,692$831,231$1,033,026
WORCESTERMA
$394,872$505,487$611,026$759,385
ANNE ARUNDELMD
$5
74,359
$7
35,282
$8
88,769
$1
,104,564
BALTIMOREMD
$574,359$735,282$888,769$1,104,564
CALVERTMD
$748,462$958,154$1,158,205$1,439,385
CARROLLMD
$574,359$735,282$888,769$1,104,564
C
ECIL
M
D
$430,769$551,436$666,564$828,410
CHARLESMD
$748,462$958,154$1,158,205$1,439,385
FREDERICKMD
$748,462$958,154$1,158,205$1,439,385
GARRETTMD
$448,718$574,410$694,359$862,923
HARFORDMD
$574,359$735,282$888,769$1,104,564
HOWARDMD
$574,359$735,282$888,769$1,104,564
KENTMD
$352,564$451,333$545,538$678,000
MONTGOMERYMD
$748,462$958,154$1,158,205$1,439,385
PRINCE GEORGE’SMD
$748,462$958,154$1,158,205$1,439,385
QUEEN ANNE’SMD
$574,359$735,282$888,769$1,104,564
ST. MARY’SMD
$410,256$525,179$634,821$788,974
SOMERSETMD
$337,179$431,641$521,744$648,410
TALBOTMD
$455,128$582,615$704,256$875,231
WASHINGTONMD
$387,179$495,641$599,128$744,564
WICOMICOMD
$337,179$431,641$521,744$648,410
2012–20 I.R.B.922May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
WORCESTERMD
$448,718$574,410$694,359$862,923
BALTIMORE CITYMD
$574,359$735,282$888,769$1,104,564
CUMBERLANDME
$346,154$443,128$535,641$665,692
HANCOCKME
$279,487$357,795$432,462$537,487
KNOXME
$286,615$366,923$443,487$551,179
LINCOLNME
$326,923$418,513$505,897$628,718
SAGADAHOCME
$346,154$443,128$535,641$665,692
YORKME
$346,154$443,128$535,641$665,692
BERRIENMI
$306,410$392,256$474,154$589,231
KALAMAZOOMI
$293,590$375,846$454,308$564,564
LAPEERMI
$305,128$390,615$472,154$586,769
LENAWEEMI
$305,128$390,615$472,154$586,769
LIVINGSTONMI
$305,128$390,615$472,154$586,769
MACOMBMI
$305,128$390,615$472,154$586,769
MONROEMI
$305,128$390,615$472,154$586,769
OAKLANDMI
$305,128$390,615$472,154$586,769
ST. CLAIRMI
$305,128$390,615$472,154$586,769
VAN BURENMI
$293,590$375,846$454,308$564,564
WASHTENAWMI
$353,846$452,974$547,538$680,462
WAYNEMI
$305,128$390,615$472,154$586,769
ANOKAMN
$374,359$479,231$579,282$719,897
CARVERMN
$374,359$479,231$579,282$719,897
CHISAG
O
MN
$374,359$479,231$579,282$719,897
COOKMN
$303,846$388,974$470,154$584,308
DAKOTAMN
$374
,359
$479
,231
$579
,282
$719
,897
HENNEPINMN
$374,359$479,231$579,282$719,897
ISANTIMN
$374,359$479,231$579,282$719,897
RAMSEYMN
$374,359$479,231$579,282$719,897
SCO
TT
MN
$374,359$479,231$579,282$719,897
SHERBURNEMN
$374,359$479,231$579,282$719,897
WASHINGTONMN
$3
74,359
$4
79,231
$5
79,282
$7
19,897
WRIGHTMN
$374,359$479,231$579,282$719,897
CRAWFORDMO
$288,462$369,282$446,359$554,718
FRANKLINMO
$
288,462
$
369,282
$
446,359
$
554,718
JEFFERSONMO
$288,462$369,282$446,359$554,718
LINCOLNMO
$288,462$369,282$446,359$554,718
ST. CHARLESMO
$288,462$369,282$446,359$554,718
ST. LOUISMO
$288,462$369,282$446,359$554,718
WARRENMO
$288,462$369,282$446,359$554,718
WASHINGTONMO
$288,462$369,282$446,359$554,718
ST. LOUIS CITYMO
$288,462$369,282$446,359$554,718
CARBONMT
$298,718$382,410$462,256$574,462
FLATHEADMT
$309,026$395,590$478,205$594,256
GALLATINMT
$396,154$507,128$613,026$761,846
JEFFERSONMT
$350,000$448,051$541,590$673,077
LAKEMT
$308,974$395,538$478,103$594,154
LEWIS AND CLARKMT
$350,000$448,051$541,590$673,077
MADISONMT
$288,974$369,949$447,179$555,692
MISSOULAMT
$298,718$382,410$462,256$574,462
May 14, 20129232012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
RAVALLIMT
$311,538$398,821$482,051$599,128
SWEET GRASSMT
$355,128$454,615$549,538$682,923
YELLOWSTONEMT
$298,718$382,410$462,256$574,462
ANSONNC
$311,538$398,821$482,051$599,128
BRUNSWICKNC
$311,538$398,821$482,051$599,128
BUNCOMBENC
$311,538$398,821$482,051$599,128
CABARRUSNC
$311,538$398,821$482,051$599,128
CAMDENNC
$748,462$958,154$1,158,205$1,439,385
CARTERETNC
$294,872$377,487$456,308$567,077
CHATHAMNC
$343,231$439,385$531,128$660,051
CURRITUCKNC
$470,615$602,462$728,256$905,026
DARENC
$471,795$603,949$730,051$907,282
DURHAMNC
$343,231$439,385$531,128$660,051
FRANKLINNC
$302,564$387,333$468,205$581,846
GASTONNC
$311,538$398,821$482,051$599,128
HAYWOODNC
$311,538$398,821$482,051$599,128
HENDERSO
N
NC
$311,538$398,821$482,051$599,128
HYDENC
$495,385$634,154$766,564$952,667
JOHNSTONNC
$302,5
64
$387,3
33
$468,2
05
$581,8
46
MADISONNC
$311,538$398,821$482,051$599,128
MECKLENBURGNC
$311,538$398,821$482,051$599,128
NEW HANOVERNC
$311,538$398,821$482,051$599,128
ONSLO
W
NC
$314,103$402,103$486,051$604,051
ORANGENC
$343,231$439,385$531,128$660,051
PASQUOTANKNC
$748
,462
$958
,154
$1,1
58,205
$1,4
39,385
PENDERNC
$311,538$398,821$482,051$599,128
PERQUIMANSNC
$748,462$958,154$1,158,205$1,439,385
PERSONNC
$343,231$439,385$531,128$660,051
TRA
NSYLVANIA
NC
$301,282$385,692$466,205$579,385
UNIONNC
$311,538$398,821$482,051$599,128
WAKENC
$3
02,564
$3
87,333
$4
68,205
$5
81,846
WATAUGANC
$292,308$374,205$452,308$562,103
BILLINGSND
$312,564$400,103$483,641$601,077
STARKND
$
312,564
$
400,103
$
483,641
$
601,077
B
ELKNAP
N
H
$288,462$369,282$446,359$554,718
GRAFTONNH
$288,462$369,282$446,359$554,718
HILLSBOROUGHNH
$412,821$528,462$638,821$793,897
MERRIMACKNH
$310,256$397,179$480,103$596,667
ROCKINGHAMNH
$537,179$687,692$831,231$1,033,026
STRAFFORDNH
$537,179$687,692$831,231$1,033,026
ATLANTICNJ
$465,385$595,744$720,154$894,974
BERGENNJ
$748,462$958,154$1,158,205$1,439,385
BURLINGTONNJ
$430,769$551,436$666,564$828,410
CAMDENNJ
$430,769$551,436$666,564$828,410
CAPE MAYNJ
$500,000$640,103$773,692$961,538
CUMBERLANDNJ
$415,385$531,744$642,769$798,821
ESSEXNJ
$748,462$958,154$1,158,205$1,439,385
GLOUCESTERNJ
$430,769$551,436$666,564$828,410
HUDSONNJ
$748,462$958,154$1,158,205$1,439,385
2012–20 I.R.B.924May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
HUNTERDONNJ
$748,462$958,154$1,158,205$1,439,385
MERCERNJ
$451,282$577,692$698,308$867,846
MIDDLESEXNJ
$748,462$958,154$1,158,205$1,439,385
MONMOUTHNJ
$748,462$958,154$1,158,205$1,439,385
MORRISNJ
$748,462$958,154$1,158,205$1,439,385
OCEANNJ
$748,462$958,154$1,158,205$1,439,385
PASSAICNJ
$748,462$958,154$1,158,205$1,439,385
SALEMNJ
$430,769$551,436$666,564$828,410
SOMERSETNJ
$748,462$958,154$1,158,205$1,439,385
SUSSEXNJ
$748,462$958,154$1,158,205$1,439,385
UNIONNJ
$748,462$958,154$1,158,205$1,439,385
WARRENNJ
$412,821$528,462$638,821$793,897
LOS ALAMOSNM
$390,410$499,795$604,103$750,769
SAN JUANNM
$288,462$369,282$446,359$554,718
SANTA FENM
$438,462$561,282$678,462$843,179
TAOSNM
$293,692$375,949$454,462$564,769
CLARKNV
$410,256$525,179$634,821$788,974
DOUGLASNV
$480,769$615,487$743,949$924,564
ELKONV
$333,333$426,718$515,795$641,026
EUREKANV
$333,333$426,718$515,795$641,026
LYONNV
$339,744$434,923$525,744$653,333
NYENV
$333,
333
$426,
718
$515,
795
$641,
026
STOREYNV
$414,103$530,103$640,769$796,359
WASHOENV
$414,103$530,103$640,769$796,359
CARSON CITYNV
$408,974$523,538$632,872$786,513
ALBANYNY
$320,513$410,308$495,949$616,359
BRONXNY
$748,462$958,154$1,158,205$1,439,385
COLUMBIANY
$283,333$362,718$438,410$544,872
DUT
CHESS
NY
$455,128$582,615$704,256$875,231
ERIENY
$283,333$362,718$438,410$544,872
KINGSNY
$7
48,462
$9
58,154
$1
,158,205
$1
,439,385
MADISONNY
$288,462$369,282$446,359$554,718
NASSAUNY
$748,462$958,154$1,158,205$1,439,385
NEW YORKNY
$748,462$958,154$1,158,205$1,439,385
N
IAGARA
N
Y
$283,333$362,718$438,410$544,872
ONONDAGANY
$288,462$369,282$446,359$554,718
ORANGENY
$455,128$582,615$704,256$875,231
OSWEGONY
$288,462$369,282$446,359$554,718
PUTNAMNY
$748,462$958,154$1,158,205$1,439,385
QUEENSNY
$748,462$958,154$1,158,205$1,439,385
RENSSELAERNY
$320,513$410,308$495,949$616,359
RICHMONDNY
$748,462$958,154$1,158,205$1,439,385
ROCKLANDNY
$748,462$958,154$1,158,205$1,439,385
SARATOGANY
$320,513$410,308$495,949$616,359
SCHENECTADYNY
$320,513$410,308$495,949$616,359
SCHOHARIENY
$320,513$410,308$495,949$616,359
SUFFOLKNY
$748,462$958,154$1,158,205$1,439,385
ULSTERNY
$416,667$533,385$644,769$801,282
WESTCHESTERNY
$748,462$958,154$1,158,205$1,439,385
May 14, 20129252012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
ASHTABULAOH
$298,718$382,410$462,256$574,462
ATHENSOH
$443,590$567,846$686,410$853,077
BROWNOH
$346,154$443,128$535,641$665,692
BUTLEROH
$346,154$443,128$535,641$665,692
CARROLLOH
$284,615$364,359$440,410$547,333
CLERMONTOH
$346,154$443,128$535,641$665,692
CUYAHOGAOH
$306,410$392,256$474,154$589,231
DELAWAREOH
$350,000$448,051$541,590$673,077
FAIRFIELDOH
$350,000$448,051$541,590$673,077
FRANKLINOH
$350,000$448,051$541,590$673,077
GEAUGAOH
$306,410$392,256$474,154$589,231
GREENEOH
$278,205$356,154$430,513$535,026
HAMILTONOH
$346,154$443,128$535,641$665,692
LAKEOH
$306,410$392,256$474,154$589,231
LICKINGOH
$350,000$448,051$541,590$673,077
LORAINOH
$306,41
0
$392,25
6
$474,15
4
$589,23
1
MADISONOH
$350,000$448,051$541,590$673,077
MEDINAOH
$306,410$392,256$474,154$589,231
MERCEROH
$300,000$384,051$464,205$576,923
MIAMIOH
$278,205$356,154$430,513$535,026
MONTGOMERYOH
$278,205$356,154$430,513$535,026
MORROWOH
$350,
000
$448,
051
$541,
590
$673,
077
PICKAWAYOH
$350,000$448,051$541,590$673,077
PORTAGEOH
$338,462$433,282$523,744$650,872
PREBLEOH
$278,205$356,154$430,513$535,026
STAR
K
OH
$284,615$364,359$440,410$547,333
SUMMITOH
$338,462$433,282$523,744$650,872
UNIONOH
$35
0,000
$44
8,051
$54
1,590
$67
3,077
VAN WERTOH
$308,974$395,538$478,103$594,154
WARRENOH
$346,154$443,128$535,641$665,692
BENTONOR
$3
46,154
$4
43,128
$5
35,641
$6
65,692
CLACKAMASOR
$429,487$549,795$664,615$825,949
CLATSOPOR
$356,410$456,256$551,538$685,385
COLUMBIAOR
$429,487$549,795$664,615$825,949
C
URRY
O
R
$360,256$461,179$557,487$692,821
DESCHUTESOR
$458,974$587,538$710,205$882,667
HOOD RIVEROR
$403,846$516,974$624,923$776,615
JACKSONOR
$433,333$554,718$670,564$833,333
JOSEPHINEOR
$333,333$426,718$515,795$641,026
LANEOR
$352,564$451,333$545,538$678,000
LINCOLNOR
$320,513$410,308$495,949$616,359
MARIONOR
$302,564$387,333$468,205$581,846
MULTNOMAHOR
$429,487$549,795$664,615$825,949
POLKOR
$302,564$387,333$468,205$581,846
TILLAMOOKOR
$352,564$451,333$545,538$678,000
WASHINGTONOR
$429,487$549,795$664,615$825,949
YAMHILLOR
$429,487$549,795$664,615$825,949
ALLEGHENYPA
$335,897$430,000$519,795$645,949
ARMSTRONGPA
$335,897$430,000$519,795$645,949
BEAVERPA
$335,897$430,000$519,795$645,949
2012–20 I.R.B.926May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
BERKSPA
$307,692$393,897$476,103$591,692
BUCKSPA
$430,769$551,436$666,564$828,410
BUTLERPA
$335,897$430,000$519,795$645,949
CARBONPA
$412,821$528,462$638,821$793,897
CENTREPA
$287,179$367,641$444,359$552,256
CHESTERPA
$430,769$551,436$666,564$828,410
DELAWAREPA
$430,769$551,436$666,564$828,410
FAYETTEPA
$335,897$430,000$519,795$645,949
LANCASTERPA
$393,590$503,846$609,026$756,923
LEHIGHPA
$412,821$528,462$638,821$793,897
MONTGOMERYPA
$430,769$551,436$666,564$828,410
NORTHAMPTONPA
$412,821$528,462$638,821$793,897
PHILADELPHIAPA
$430,769$551,436$666,564$828,410
PIKEPA
$748,462$958,154$1,158,205$1,439,385
WASHINGTONPA
$335,897$430,000$519,795$645,949
WESTMORELANDPA
$335,89
7
$430,00
0
$519,79
5
$645,94
9
YORKPA
$435,897$558,000$674,513$838,256
BRISTOLRI
$487,179$623,692$753,897$936,872
KENTRI
$487,1
79
$623,6
92
$753,8
97
$936,8
72
NEWPORTRI
$487,179$623,692$753,897$936,872
PROVIDENCERI
$487,179$623,692$753,897$936,872
WASHINGTONRI
$487,179$623,692$753,897$936,872
BEAUFORTSC
$397,436$508,769$614,974$764,308
BERKELEYSC
$343,590$439,846$531,692$660,769
CHARLESTONSC
$343,590$439,846$531,692$660,769
DORC
HESTER
SC
$343,590$439,846$531,692$660,769
GEORGETOWNSC
$405,128$518,615$626,923$779,077
GREENVILLESC
$30
2,564
$38
7,333
$46
8,205
$58
1,846
HORRYSC
$293,590$375,846$454,308$564,564
JASPERSC
$397,436$508,769$614,974$764,308
LAURENSSC
$302,564$387,333$468,205$581,846
PI
CKENS
SC
$302,564$387,333$468,205$581,846
YORKSC
$311,538$398,821$482,051$599,128
CANNONTN
$443,590$567,846$686,410$853,077
C
HEATHAM
T
N
$443,590$567,846$686,410$853,077
DAVIDSONTN
$443,590$567,846$686,410$853,077
DICKSONTN
$443,590$567,846$686,410$853,077
HICKMANTN
$443,590$567,846$686,410$853,077
MACONTN
$443,590$567,846$686,410$853,077
ROBERTSONTN
$443,590$567,846$686,410$853,077
RUTHERFORDTN
$443,590$567,846$686,410$853,077
SMITHTN
$443,590$567,846$686,410$853,077
SUMNERTN
$443,590$567,846$686,410$853,077
TROUSDALETN
$443,590$567,846$686,410$853,077
WILLIAMSONTN
$443,590$567,846$686,410$853,077
WILSONTN
$443,590$567,846$686,410$853,077
ATASCOSATX
$341,026$436,564$527,692$655,795
BANDERATX
$341,026$436,564$527,692$655,795
BASTROPTX
$296,154$379,128$458,256$569,538
May 14, 20129272012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
BEXARTX
$341,026$436,564$527,692$655,795
CALDWELLTX
$296,154$379,128$458,256$569,538
COMALTX
$341,026$436,564$527,692$655,795
GUADALUPETX
$341,026$436,564$527,692$655,795
HAYSTX
$296,154$379,128$458,256$569,538
JEFF DAVISTX
$278,205$356,154$430,513$535,026
KENDALLTX
$341,026$436,564$527,692$655,795
MEDINATX
$341,026$436,564$527,692$655,795
TRAVISTX
$296,154$379,128$458,256$569,538
WILLIAMSONTX
$296,154$379,128$458,256$569,538
WILSONTX
$341,026$436,564$527,692$655,795
DAGGETTUT
$310,205$397,128$480,000$596,564
DAVISUT
$407,692$521,897$630,872$784,000
JUABUT
$332,051$425,077$513,795$638,564
KANEUT
$393,590$503,846$609,026$756,923
MORGANUT
$407,692$521,897$630,872$784,000
RICHUT
$304,308$389,538$470,872$585,179
SALT LAKEUT
$748,462$958,154$1,158,205$1,439,385
SUMMITUT
$748,4
62
$958,1
54
$1,158
,205
$1,439
,385
TOOELEUT
$748,462$958,154$1,158,205$1,439,385
UTAHUT
$332,051$425,077$513,795$638,564
WASATCHUT
$442,308$566,205$684,462$850,615
WASHI
NGTON
UT
$382,051$489,077$591,179$734,718
WEBERUT
$407,692$521,897$630,872$784,000
ALBEMARLEVA
$448,205$573,795$693,538$861,949
AMEL
IA
VA
$549,641$703,641$850,513$1,057,026
AMHERSTVA
$299,590$383,538$463,590$576,103
APPOMATTOXVA
$29
9,590
$38
3,538
$46
3,590
$57
6,103
ARLINGTONVA
$748,462$958,154$1,158,205$1,439,385
BEDFORDVA
$299,590$383,538$463,590$576,103
BOTETOURTVA
$287,179$367,641$444,359$552,256
CA
MPBELL
VA
$299,590$383,538$463,590$576,103
CAROLINEVA
$549,641$703,641$850,513$1,057,026
CHARLES CITYVA
$
549,641
$
703,641
$
850,513
$
1,057,026
CHESTERFIELDVA
$549,641$703,641$850,513$1,057,026
CLARKEVA
$748,462$958,154$1,158,205$1,439,385
CRAIGVA
$287,179$367,641$444,359$552,256
CULPEPERVA
$392,308$502,205$607,077$754,462
CUMBERLANDVA
$549,641$703,641$850,513$1,057,026
DINWIDDIEVA
$549,641$703,641$850,513$1,057,026
ESSEXVA
$384,615$492,359$595,179$739,641
FAIRFAXVA
$748,462$958,154$1,158,205$1,439,385
FAUQUIERVA
$748,462$958,154$1,158,205$1,439,385
FLUVANNAVA
$448,205$573,795$693,538$861,949
FRANKLINVA
$287,179$367,641$444,359$552,256
FREDERICKVA
$487,179$623,692$753,897$936,872
GILESVA
$299,590$383,538$463,590$576,103
GLOUCESTERVA
$470,615$602,462$728,256$905,026
GOOCHLANDVA
$549,641$703,641$850,513$1,057,026
GREENEVA
$448,205$573,795$693,538$861,949
2012–20 I.R.B.928May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
HANOVERVA
$549,641$703,641$850,513$1,057,026
HENRICOVA
$549,641$703,641$850,513$1,057,026
HIGHLANDVA
$294,872$377,487$456,308$567,077
ISLE OF WIGHTVA
$470,615$602,462$728,256$905,026
JAMES CITYVA
$470,615$602,462$728,256$905,026
KING AND QUEENVA
$549,641$703,641$850,513$1,057,026
KING GEORGEVA
$396,154$507,128$613,026$761,846
KING WILLIAMVA
$549,641$703,641$850,513$1,057,026
LANCASTERVA
$558,974$715,590$864,974$1,074,974
LOUDOUNVA
$748,462$958,154$1,158,205$1,439,385
LOUISAVA
$549,641$703,641$850,513$1,057,026
MADISONVA
$284,615$364,359$440,410$547,333
MATHEWSVA
$470,615$602,462$728,256$905,026
MIDDLESEXVA
$338,462$433,282$523,744$650,872
MONTGOMERYVA
$299,590$383,538$463,590$576,103
NELSONVA
$448,20
5
$573,79
5
$693,53
8
$861,94
9
NEW KENTVA
$549,641$703,641$850,513$1,057,026
NORTHUMBERLANDVA
$402,564$515,333$622,923$774,154
ORANGEVA
$339,744$434,923$525,744$653,333
POWHAT
AN
VA
$549,641$703,641$850,513$1,057,026
PRINCE GEORGEVA
$549,641$703,641$850,513$1,057,026
PRINCE WILLIAMVA
$748,
462
$958,
154
$1,15
8,205
$1,43
9,385
PULASKIVA
$299,590$383,538$463,590$576,103
RAPPAHANNOCKVA
$369,179$472,615$571,282$709,949
RICHMONDVA
$307,692$393,897$476,103$591,692
ROAN
OKE
VA
$287,179$367,641$444,359$552,256
ROCKINGHAMVA
$284,256$363,897$439,846$546,615
SPOTSYLVANIAVA
$74
8,462
$95
8,154
$1,
158,205
$1,
439,385
STAFFORDVA
$748,462$958,154$1,158,205$1,439,385
SURRYVA
$470,615$602,462$728,256$905,026
SUSSEXVA
$549,641$703,641$850,513$1,057,026
WA
RREN
VA
$748,462$958,154$1,158,205$1,439,385
YORKVA
$470,615$602,462$728,256$905,026
ALEXANDRIAVA
$
748,462
$
958,154
$
1,158,205
$
1,439,385
BEDFORD INDVA
$299,590$383,538$463,590$576,103
CHARLOTTESVILLEVA
$448,205$573,795$693,538$861,949
CHESAPEAKEVA
$470,615$602,462$728,256$905,026
COLONIAL HEIGHTVA
$549,641$703,641$850,513$1,057,026
FAIRFAX INDVA
$748,462$958,154$1,158,205$1,439,385
FALLS CHURCHVA
$748,462$958,154$1,158,205$1,439,385
FREDERICKSBURGVA
$748,462$958,154$1,158,205$1,439,385
HAMPTONVA
$470,615$602,462$728,256$905,026
HARRISONBURGVA
$284,256$363,897$439,846$546,615
HOPEWELLVA
$549,641$703,641$850,513$1,057,026
LEXINGTONVA
$303,846$388,974$470,154$584,308
LYNCHBURGVA
$299,590$383,538$463,590$576,103
MANASSASVA
$748,462$958,154$1,158,205$1,439,385
MANASSAS PARKVA
$748,462$958,154$1,158,205$1,439,385
NEWPORT NEWSVA
$470,615$602,462$728,256$905,026
NORFOLKVA
$470,615$602,462$728,256$905,026
May 14, 20129292012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
PETERSBURGVA
$549,641$703,641$850,513$1,057,026
POQUOSONVA
$470,615$602,462$728,256$905,026
PORTSMOUTHVA
$470,615$602,462$728,256$905,026
RADFORDVA
$299,590$383,538$463,590$576,103
RICHMOND INDVA
$549,641$703,641$850,513$1,057,026
ROANOKE INDVA
$287,179$367,641$444,359$552,256
SALEMVA
$287,179$367,641$444,359$552,256
SUFFOLKVA
$470,615$602,462$728,256$905,026
VIRGINIA BEACHVA
$470,615$602,462$728,256$905,026
WILLIAMSBURGVA
$470,615$602,462$728,256$905,026
WINCHESTERVA
$487,179$623,692$753,897$936,872
BENNINGTONVT
$284,256$363,897$439,846$546,615
CHITTENDENVT
$326,923$418,513$505,897$628,718
FRANKLINVT
$326,923$418,513$505,897$628,718
GRAND ISLEVT
$326,923$418,513$505,897$628,718
LAMOILLEVT
$283,077$362,359$438,051$544,359
ORANGEVT
$288,462$369,282$446,359$554,718
WINDSORVT
$288,462$369,282$446,359$554,718
BENTONWA
$282,051$361,077$436,462$542,410
CHELANWA
$351,487$449,949$543,897$675,949
CLALLAMWA
$393,949$504,308$609,590$757,590
CLARKWA
$429,
487
$549,
795
$664,
615
$825,
949
DOUGLASWA
$351,487$449,949$543,897$675,949
FRANKLINWA
$282,051$361,077$436,462$542,410
ISLANDWA
$391,026$500,564$605,077$751,949
JEFF
ERSON
WA
$448,718$574,410$694,359$862,923
KINGWA
$582,051$745,128$900,667$1,119,333
KITSAPWA
$48
7,179
$62
3,692
$75
3,897
$93
6,872
KITTITASWA
$337,179$431,641$521,744$648,410
MASONWA
$317,949$407,026$492,000$611,436
PIERCEWA
$582,051$745,128$900,667$1,119,333
SA
NJUAN
WA
$608,974$779,590$942,359$1,171,128
SKAGITWA
$383,333$490,718$593,179$737,179
SKAMANIAWA
$
429,487
$
549,795
$
664,615
$
825,949
SNOHOMISHWA
$582,051$745,128$900,667$1,119,333
THURSTONWA
$370,513$474,308$573,333$712,513
WHATCOMWA
$384,615$492,359$595,179$739,641
COLUMBIAWI
$301,282$385,692$466,205$579,385
DANEWI
$301,282$385,692$466,205$579,385
IOWAWI
$301,282$385,692$466,205$579,385
KENOSHAWI
$420,513$538,308$650,718$808,667
MILWAUKEEWI
$323,077$413,590$499,949$621,282
OZAUKEEWI
$323,077$413,590$499,949$621,282
PIERCEWI
$374,359$479,231$579,282$719,897
ST. CROIXWI
$374,359$479,231$579,282$719,897
WALWORTHWI
$285,897$366,000$442,410$549,795
WASHINGTONWI
$323,077$413,590$499,949$621,282
WAUKESHAWI
$323,077$413,590$499,949$621,282
BERKELEYWV
$387,179$495,641$599,128$744,564
2012–20 I.R.B.930May 14, 2012

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
HAMPSHIREWV
$487,179$623,692$753,897$936,872
JEFFERSONWV
$748,462$958,154$1,158,205$1,439,385
MORGANWV
$387,179$495,641$599,128$744,564
SHERIDANWY
$279,487$357,795$432,462$537,487
SUBLETTEWY
$306,410$392,256$474,154$589,231
TETONWY
$711,538$910,872$1,101,077$1,368,359
MANUAAS
$312,821$400,462$484,051$601,590
GUAMGU
$667,949$855,077$1,033,590$1,284,513
NORTHERN ISLANDMP
$620,513$794,359$960,205$1,193,333
ROTAMP
$485,897$622,051$751,897$934,410
SAIPANMP
$625,641$800,923$968,154$1,203,179
TINIANMP
$629,487$805,846$974,103$1,210,564
AGUAS BUENASPR
$621,795$796,000$962,205$1,195,79
5
AIBONITOPR
$621,795$796,000$962,205$1,195,795
ARECIBOPR
$621,795$796,000$962,205$1,195,795
BARCELONETAPR
$621,795$796,000$962,205$1,195,795
BARRANQU
ITAS
PR
$621,795$796,000$962,205$1,195,795
BAYAMONPR
$621,795$796,000$962,205$1,195,795
CAGUASPR
$621,79
5
$796,00
0
$962,20
5
$1,195,
795
CAMUYPR
$621,795$796,000$962,205$1,195,795
CANOVANASPR
$621,795$796,000$962,205$1,195,795
CAROLINAPR
$621,795$796,000$962,205$1,195,795
CATANOPR
$621,795$796,000$962,205$1,195,795
CAYEYPR
$621,795$796,000$962,205$1,195,795
CEIBAPR
$333,
333
$426,
718
$515,
795
$641,
026
CIALESPR
$621,795$796,000$962,205$1,195,795
CIDRAPR
$621,795$796,000$962,205$1,195,795
COMERIOPR
$621,795$796,000$962,205$1,195,795
CORO
ZAL
PR
$621,795$796,000$962,205$1,195,795
DORADOPR
$621,795$796,000$962,205$1,195,795
FAJARDOPR
$33
3,333
$42
6,718
$51
5,795
$64
1,026
FLORIDAPR
$621,795$796,000$962,205$1,195,795
GUAYNABOPR
$621,795$796,000$962,205$1,195,795
GURABOPR
$621,795$796,000$962,205$1,195,795
HA
TILLO
P
R
$621,795$796,000$962,205$1,195,795
HUMACAOPR
$621,795$796,000$962,205$1,195,795
JUNCOSPR
$
621,795
$
796,000
$
962,205
$
1,195,795
LAS PIEDRASPR
$621,795$796,000$962,205$1,195,795
LOIZAPR
$621,795$796,000$962,205$1,195,795
LUQUILLOPR
$333,333$426,718$515,795$641,026
MANATIPR
$621,795$796,000$962,205$1,195,795
MAUNABOPR
$621,795$796,000$962,205$1,195,795
MOROVISPR
$621,795$796,000$962,205$1,195,795
NAGUABOPR
$621,795$796,000$962,205$1,195,795
NARANJITOPR
$621,795$796,000$962,205$1,195,795
OROCOVISPR
$621,795$796,000$962,205$1,195,795
QUEBRADILLASPR
$621,795$796,000$962,205$1,195,795
RIO GRANDEPR
$621,795$796,000$962,205$1,195,795
SAN JUANPR
$621,795$796,000$962,205$1,195,795
May 14, 20129312012–20 I.R.B.

2012 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit
SAN LORENZOPR
$621,795$796,000$962,205$1,195,795
TOA ALTAPR
$621,795$796,000$962,205$1,195,795
TOA BAJAPR
$621,795$796,000$962,205$1,195,795
TRUJILLO ALTOPR
$621,795$796,000$962,205$1,195,795
VEGA ALTAPR
$621,795$796,000$962,205$1,195,795
VEGA BAJAPR
$621,795$796,000$962,205$1,195,795
YABUCOAPR
$621,795$796,000$962,205$1,195,795
ST. CROIXVI
$336,154$430,308$520,154$646,462
ST. JOHNVI
$639,282$818,410$989,231$1,229,385
ST. THOMASVI
$457,641$585,846$708,154$880,103
All other areas (floor):
$278,000$355,897$430,154$534,615
.02 The nationwideaverage purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$214,000.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2011–23 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area pur-
chase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if the
purchase precedes the commitment) for
residences that are purchased, in the period
that begins on April 25, 2012, and ends
on the date as of which the safe harbors
contained in section 4.01 of this revenue
procedure are rendered obsolete by a new
revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc.
2011–23, with respect to bonds sold, or for
mortgage credit certificates issued with
respect to bond authority exchanged, be-
fore May 25, 2012, if the commitments to
provide financing or issue mortgage credit
certificates are made on or before June 24,
2012.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in
this revenue procedure for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if
the purchase precedes the commitment)
for residences that are purchased, in the
period that begins on April 25, 2012, and
ends on the date when the nationwide av-
erage purchase price limitation is rendered
obsolete by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2011–23 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before May 25, 2012, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
June 24, 2012.
SECTION 7. REQUEST FOR
COMMENTS
Code section 143 requires that the av-
erage area purchase prices be based on the
most recent 12-month period for which
sufficient statistical information is avail-
able. In order to ensure that the safe har-
bors reflect accurate and timely price infor-
mation, the Treasury Department and the
IRS are considering possible changes in
the data source and method used for these
safe harbors beginning in 2013. The alter-
native method under consideration would
involve the use of certain currently avail-
able data from the Department of Housing
and Urban Development (“HUD”) re-
garding county median housing purchase
prices instead of the FHA loan limits. Cer-
tain aggregate HUD price data are avail-
able athttp://www.hud.gov/pub/chums
under CY2012 FHA Forward Limits,
and certain HUD price data for
individual counties is available at
https://entp.hud.gov/idapp/html/hicostlook.cfm.
Absent modifications, the use of HUD
data on county median housing purchase
prices potentially would result in signifi-
cant declines in purchase price limits com-
pared to prior limits, particularly in ru-
ral areas. The Treasury Department and
the IRS are considering certain appropri-
ate modifications to the HUD price data in
implementing this alternative method.
One potential modification would be
to consider setting floors on purchase
price safe harbors. Potential approaches
to setting floors on purchase prices might
include national average prices, county av-
erage prices, rural county average prices,
or some percentile of county average
prices. For illustrative purposes only, set
forth below are the floors on mean pur-
chase prices that would result from using
one of these approaches with 2012 data:
(1) national average price ($214,000); (2)
county average price ($174,862); (3) ru-
ral county average price ($112,864); (4)
25
th
percentile of county average price
($92,308); (5) 50
th
percentile of county
average price ($138,462); or (6) 75
th
per-
centile of county average price ($214,103).
Another potential modification would
be to consider transitional relief to phase
in the effects of the changes over an ex-
tended period, as compared with a base-
line of the 2012 purchase price safe har-
bors in section 4.01 of this revenue proce-
dure. Potential phase-in periods might in-
clude a period of three years to five years.
In addition, a technical modification will
make adjustments for differences between
2012–20 I.R.B.932May 14, 2012

HUD median prices and the required aver-
age prices.
The Treasury Department and the IRS
solicit public comments on this alternative
method using current HUD data on county
median housing purchase prices, includ-
ing particularly comments on potential
floors on prices and phase-in periods for
the method, and on whether other methods
or data sources should be used to calculate
these safe harbors. Comments should be
submitted in writing and can be e-mailed
tonotice.comments@irscounsel.treas.gov
(include “Rev. Proc. 2012–25” in the
subject line) or mailed to Office of Asso-
ciate Chief Counsel (Financial Institutions
& Products), Re: Rev. Proc. 2012–25,
CC:FIP:B5, Room 3547, 1111 Constitu-
tion Avenue, NW, Washington, DC 20224.
The due date for the public comments is
July 15, 2012. Comments that are submit-
ted will be made available to the public.
SECTION 8. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
reviewed and approved by the Office
of Management and Budget in accor-
dance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545–1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a col-
lection of information requirement in sec-
tion 3.03. The purpose of the collection
of information is to verify the applica-
ble FHA loan limit that issuers of quali-
fied mortgage bonds and qualified mort-
gage certificates have used to calculate the
average area purchase price for a given
metropolitan statistical area for purposes
of section 143(e) and 25(c). The collec-
tion of information is required to obtain
the benefit of using revisions to FHA loan
limits to determine average area purchase
prices. The likely respondents are state
and local governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per re-
spondent and/or recordkeeper: 15 minutes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
SECTION 9. DRAFTING
INFORMATION
The principal authors of this rev-
enue procedure are David E. White
and Timothy L. Jones of the Office
of Associate Chief Counsel (Financial
Institutions & Products). For further
information regarding this revenue
procedure, contact David E. White at (202)
622–3980 (not a toll-free call).
26 CFR 601.602: Tax forms and instructions.
(Also: Part 1, §§ 1, 223.)
Rev. Proc. 2012–26
SECTION 1. PURPOSE
This revenue procedure provides the
2013 inflation adjusted amounts for Health
Savings Accounts (HSAs) as determined
under § 223 of the Internal Revenue Code.
SECTION 2. 2013 INFLATION
ADJUSTED ITEMS
Annual contribution limitation. For cal-
endar year 2013, the annual limitation on
deductions under § 223(b)(2)(A) for an in-
dividual with self-only coverage under a
high deductible health plan is $3,250. For
calendar year 2013, the annual limitation
on deductions under § 223(b)(2)(B) for an
individual with family coverage under a
high deductible health plan is $6,450.
High deductible health plan. For cal-
endar year 2013, a “high deductible health
plan” is defined under § 223(c)(2)(A) as
a health plan with an annual deductible
that is not less than $1,250 for self-only
coverage or $2,500 for family coverage,
and the annual out-of-pocket expenses
(deductibles, co-payments, and other
amounts, but not premiums) do not exceed
$6,250 for self-only coverage or $12,500
for family coverage.
SECTION 3. EFFECTIVE DATE
This revenue procedure is effective for
calendar year 2013.
SECTION 4. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Bill Ruane of Office of
Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding § 223 and HSAs, contact
Leslie Paul at (202) 622–6080 (not a
toll-free call). For further information
regarding the calculation of the inflation
adjustments in this revenue procedure,
contact Mr. Ruane at (202) 622–4920 (not
a toll-free call).
May 14, 20129332012–20 I.R.B.

Part IV. Items o
fGeneralInterest
Reporting Inf
ormation
Regarding Joi
nt Ventures
and Other Part
nerships on
Forms 990 and
990–EZ for
Tax Year 2011
Announcemen
t 2012–19
This announc
ement notifies filers of
Form 990,Ret
urn of Organization Exempt
from Income T
axandForm 990–EZ,Short
Form Return
of Organization Exempt from
Income Tax,
of a change in the 2011 Form
990–EZ and F
orm 990Instructions.Ex-
cept as note
d below, it is nowoptionalfor
tax year 20
11 for filers to report their in-
terests in
the income, expenses, and assets
of joint ve
ntures and other partnerships
in which th
ey have an ownership interest
using info
rmation fromForm 1065,U.S.
Return of
Partnership Income,Schedule
K–1.
The2010 F
orm 990 Instructionsstate,
inAppend
ix F, that the filing organization
should re
port in Parts VIII, IX, and X its
proporti
onate interests in a joint venture’s
or other
partnership’s revenue, expenses,
and asse
ts in accordance with the organ-
ization
’s books and records. To promote
greater
consistency, accuracy, and trans-
parency
in reporting this information,
includ
ing unrelated business income from
partne
rships, the IRS revised the2011
Form 990 and Fo
rm 990–EZ Instructions
to require the
filingorganizationtoreport
such interest
s using information from the
Form 1065, Sch
edule K–1 provided by the
partnership.
Since publish
ing the 2011 Form 990
and Form 990–E
Z Instructions in January
2012, the IRS
has received comments from
the public ar
guing that reporting organiza-
tions’ inter
ests in partnership assets using
the organiza
tion’s books and records pro-
vides a more
accurate value of those assets
than does re
porting using Schedule K–1
informatio
n. Other commenters noted that
using Sched
ule K–1 information can be
burdensom
e and that organizations cannot
report inf
ormation from all Forms 1065,
Schedules
K–1 they receive because some
partnersh
ips do not submit those Forms
until afte
r the Form 990 filing due date. To
more full
y consider these comments, and
to determ
ine how best to promote com-
pliance a
nd transparency while minimiz-
ing burde
n in reporting of partnership in-
terests
, the IRS has decided to make the
new Sche
dule K–1 reporting instructions
for Form
s 990 and 990–EZ optional for tax
year 201
1.
In repor
ting on the 2011 Form 990 or
Form 990
–EZ its proportionate interests
in the in
come, expenses, and assets of
partne
rships in which it has an ownership
intere
st, an organization generally may
contin
ue to report these interests based on
its books and r
ecords. However, as in prior
years, organi
zations that completeForm
990,Schedule
HandForm 990,Schedule
Rmust continu
e to use information from
Form 1065, Sch
edule K–1 in reporting
certain part
nership information on those
schedules, a
s explained in the instructions
for 2011 Form
990, Schedule H and 2011
Form 990, Sch
edule R.
The IRS welco
mes further comments
on whether an
d how the use of Form 1065,
Schedule K–
1 in reporting certain infor-
mationonpa
rtnerships, as is currently
required on
Schedules H and R, should
be extended
to Parts VIII–X of the core
Form 990, F
orm 990–EZ, and/or to other
schedules
. Comments may be submitted
toForm990
Revision@irs.govor to:
Internal R
evenue Service
Attn: Step
hen Clarke
(Announc
ement 2012–19)
SE:T:EO
1111 Cons
titution Avenue, N.W. –
NCA 570–1
4
Washingt
on, D.C. 20224
The princ
ipal author of this announce-
ment is S
tephen Clarke of the Tax Ex-
empt and
Government Entities Division.
For furt
her information regarding this an-
nouncem
ent, please contact Mr. Clarke at
(202) 28
3–9474 (not a toll-free number).
2012–20 I.R.B.934May 14, 2012

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
May 14, 2012i2012–20 I.R.B.

Numerical Finding List
1
Bulletins 2012–1 through 2012–20
Announcements:
2012-1, 2012-1 I.R.B.249
2012-2, 2012-2 I.R.B.285
2012-3, 2012-4 I.R.B.335
2012-4, 2012-4 I.R.B.335
2012-5, 2012-5 I.R.B.348
2012-6, 2012-6 I.R.B.366
2012-7, 2012-6 I.R.B.367
2012-8, 2012-7 I.R.B.373
2012-9, 2012-7 I.R.B.377
2012-11, 2012-13 I.R.B.611
2012-12, 2012-12 I.R.B.562
2012-13, 2012-16 I.R.B.805
2012-14, 2012-14 I.R.B.721
2012-15, 2012-15 I.R.B.794
2012-16, 2012-18 I.R.B.876
2012-17, 2012-18 I.R.B.876
2012-18, 2012-16 I.R.B.845
2012-19, 2012-20 I.R.B.934
2012-20, 2012-18 I.R.B.876
2012-21, 2012-19 I.R.B.898
2012-22, 2012-19 I.R.B.899
Notices:
2012-1, 2012-2 I.R.B.260
2012-3, 2012-3 I.R.B.289
2012-4, 2012-3 I.R.B.290
2012-5, 2012-3 I.R.B.291
2012-6, 2012-3 I.R.B.293
2012-7, 2012-4 I.R.B.308
2012-8, 2012-4 I.R.B.309
2012-9, 2012-4 I.R.B.315
2012-10, 2012-5 I.R.B.343
2012-11, 2012-5 I.R.B.346
2012-12, 2012-6 I.R.B.365
2012-13, 2012-9 I.R.B.421
2012-14, 2012-8 I.R.B.411
2012-15, 2012-9 I.R.B.424
2012-16, 2012-9 I.R.B.427
2012-17, 2012-9 I.R.B.430
2012-18, 2012-10 I.R.B.438
2012-19, 2012-10 I.R.B.440
2012-20, 2012-13 I.R.B.574
2012-21, 2012-10 I.R.B.450
2012-22, 2012-13 I.R.B.576
2012-23, 2012-11 I.R.B.483
2012-24, 2012-13 I.R.B.578
2012-25, 2012-15 I.R.B.789
2012-26, 2012-17 I.R.B.847
2012-27, 2012-17 I.R.B.849
2012-28, 2012-17 I.R.B.850
2012-29, 2012-18 I.R.B.872
Notices— Continued:
2012-30, 2012-18 I.R.B.874
2012-31, 2012-20 I.R.B.906
2012-32, 2012-20 I.R.B.910
2012-33, 2012-20 I.R.B.912
Proposed Regulations:
REG-168745-03, 2012-14 I.R.B.718
REG-109369-10, 2012-9 I.R.B.434
REG-110980-10, 2012-13 I.R.B.581
REG-113770-10, 2012-13 I.R.B.587
REG-113903-10, 2012-11 I.R.B.486
REG-120282-10, 2012-11 I.R.B.487
REG-130302-10, 2012-8 I.R.B.412
REG-135491-10, 2012-16 I.R.B.803
REG-149625-10, 2012-2 I.R.B.279
REG-102988-11, 2012-4 I.R.B.326
REG-115809-11, 2012-13 I.R.B.598
REG-124627-11, 2012-8 I.R.B.417
REG-124791-11, 2012-15 I.R.B.791
REG-130777-11, 2012-5 I.R.B.347
REG-132736-11, 2012-15 I.R.B.793
REG-135071-11, 2012-12 I.R.B.561
REG-136008-11, 2012-19 I.R.B.881
REG-141268-11, 2012-19 I.R.B.896
REG-145474-11, 2012-11 I.R.B.495
Revenue Procedures:
2012-1, 2012-1 I.R.B.1
2012-2, 2012-1 I.R.B.92
2012-3, 2012-1 I.R.B.113
2012-4, 2012-1 I.R.B.125
2012-5, 2012-1 I.R.B.169
2012-6, 2012-1 I.R.B.197
2012-7, 2012-1 I.R.B.232
2012-8, 2012-1 I.R.B.235
2012-9, 2012-2 I.R.B.261
2012-10, 2012-2 I.R.B.273
2012-11, 2012-7 I.R.B.368
2012-12, 2012-2 I.R.B.275
2012-13, 2012-3 I.R.B.295
2012-14, 2012-3 I.R.B.296
2012-15, 2012-7 I.R.B.369
2012-16, 2012-10 I.R.B.452
2012-17, 2012-10 I.R.B.453
2012-18, 2012-10 I.R.B.455
2012-19, 2012-14 I.R.B.689
2012-20, 2012-14 I.R.B.700
2012-21, 2012-11 I.R.B.484
2012-22, 2012-17 I.R.B.853
2012-23, 2012-14 I.R.B.712
2012-24, 2012-20 I.R.B.913
2012-25, 2012-20 I.R.B.914
2012-26, 2012-20 I.R.B.933
Revenue Rulings:
2012-1, 2012-2 I.R.B.255
2012-2, 2012-3 I.R.B.286
2012-3, 2012-8 I.R.B.383
2012-4, 2012-8 I.R.B.386
2012-5, 2012-5 I.R.B.337
2012-6, 2012-6 I.R.B.349
2012-7, 2012-6 I.R.B.362
2012-8, 2012-13 I.R.B.563
2012-9, 2012-11 I.R.B.475
2012-10, 2012-14 I.R.B.614
2012-11, 2012-14 I.R.B.686
2012-12, 2012-15 I.R.B.748
2012-13, 2012-19 I.R.B.878
Treasury Decisions:
9559, 2012-2 I.R.B.252
9560, 2012-4 I.R.B.299
9561, 2012-5 I.R.B.341
9562, 2012-5 I.R.B.339
9563, 2012-6 I.R.B.354
9564, 2012-14 I.R.B.614
9565, 2012-8 I.R.B.378
9566, 2012-8 I.R.B.389
9567, 2012-8 I.R.B.395
9568, 2012-12 I.R.B.499
9569, 2012-11 I.R.B.465
9570, 2012-11 I.R.B.477
9571, 2012-11 I.R.B.468
9572, 2012-11 I.R.B.471
9573, 2012-12 I.R.B.498
9574, 2012-12 I.R.B.559
9575, 2012-15 I.R.B.749
9576, 2012-15 I.R.B.723
9577, 2012-15 I.R.B.730
9579, 2012-16 I.R.B.796
9580, 2012-16 I.R.B.801
9581, 2012-16 I.R.B.798
9582, 2012-18 I.R.B.868
9583, 2012-18 I.R.B.866
9584, 2012-20 I.R.B.900
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2011–27 through 2011–52 is in Internal Revenue Bulletin
2011–52, dated December 27, 2011.
2012–20 I.R.B.iiMay 14, 2012

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2012–1 through 2012–20
Announcements:
2002-44
Supplemented by
Notice 2012-13, 2012-9 I.R.B.421
2010-19
Obsoleted by
Ann. 2012-12, 2012-12 I.R.B.562
2011-63
Corrected by
Ann. 2012-9, 2012-7 I.R.B.377
Notices:
2006-52
As clarified and amplified by Notice 2008-40, is
modified by
Notice 2012-26, 2012-17 I.R.B.847
2006-87
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2006-99
Superseded in part by
Notice 2012-20, 2012-13 I.R.B.574
2007-25
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2007-77
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2007-95
Obsoleted in part by
T.D. 9576, 2012-15 I.R.B.723
2008-98
Modified by
Notice 2012-29, 2012-18 I.R.B.872
2008-107
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2009-86
Modified by
Notice 2012-29, 2012-18 I.R.B.872
2010-27
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2010-88
As modified by Ann. 2011-40, is superseded by
Notice 2012-1, 2012-2 I.R.B.260
Notices— Continued:
2010-92
Obsoleted by
T.D. 9577, 2012-15 I.R.B.730
2011-8
Superseded by
Notice 2012-19, 2012-10 I.R.B.440
2011-28
Superseded by
Notice 2012-9, 2012-4 I.R.B.315
Proposed Regulations:
REG-208274-86
Withdrawn by
Ann. 2012-11, 2012-13 I.R.B.611
Revenue Procedures:
2000-43
Amplified, modified and superseded by
Rev. Proc. 2012-18, 2012-10 I.R.B.455
2003-61
Superseded by
Notice 2012-8, 2012-4 I.R.B.309
2007-44
Modified by
Ann. 2012-3, 2012-4 I.R.B.335
2010-43
Superseded by
Rev. Proc. 2012-22, 2012-17 I.R.B.853
2011-1
Superseded by
Rev. Proc. 2012-1, 2012-1 I.R.B.1
2011-2
Superseded by
Rev. Proc. 2012-2, 2012-1 I.R.B.92
2011-3
Superseded by
Rev. Proc. 2012-3, 2012-1 I.R.B.113
2011-4
Superseded by
Rev. Proc. 2012-4, 2012-1 I.R.B.125
2011-5
Superseded by
Rev. Proc. 2012-5, 2012-1 I.R.B.169
2011-6
Superseded by
Rev. Proc. 2012-6, 2012-1 I.R.B.197
2011-7
Superseded by
Rev. Proc. 2012-7, 2012-1 I.R.B.232
Revenue Procedures— Continued:
2011-8
Superseded by
Rev. Proc. 2012-8, 2012-1 I.R.B.235
2011-9
Superseded by
Rev. Proc. 2012-9, 2012-2 I.R.B.261
2011-10
Superseded by
Rev. Proc. 2012-10, 2012-2 I.R.B.273
2011-14
Modified and clarified by
Rev. Proc. 2012-19, 2012-14 I.R.B.689
Rev. Proc. 2012-20, 2012-14 I.R.B.700
2011-23
Obsoleted in part by
Rev. Proc. 2012-25, 2012-20 I.R.B.914
2011-37
Obsoleted in part by
Rev. Proc. 2012-16, 2012-10 I.R.B.452
2011-40
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2011-49
Modified by
Ann. 2012-3, 2012-4 I.R.B.335
2011-50
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2011-51
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2011-62
Corrected by
Ann. 2012-17, 2012-18 I.R.B.876
2012-8
Corrected by
Ann. 2012-7, 2012-6 I.R.B.367
Revenue Rulings:
92-19
Supplemented in part by
Rev. Rul. 2012-6, 2012-6 I.R.B.349
2008-40
Modified by
Notice 2012-6, 2012-3 I.R.B.293
2011-1
Modified by
Notice 2012-6, 2012-3 I.R.B.293
2012-9
Modified by
Rev. Rul. 2012-12, 2012-15 I.R.B.748
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2011–27 through 2011–52 is in Internal Revenue Bulletin 2011–52, dated December 27,
2011.
May 14, 2012iii2012–20 I.R.B.

Treasury Decision:
9517
Corrected by
Ann. 2012-4, 2012-4 I.R.B.335
Ann. 2012-5, 2012-5 I.R.B.348
2012–20 I.R.B.ivMay 14, 2012

May 14, 20122012–20 I.R.B.

2012–20 I.R.B.May 14, 2012

May 14, 20122012–20 I.R.B.

Internal Revenue Service
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