Internal Revenue Bulletin 2012-45 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 201
2-45
November 5, 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.
SPECIAL ANNOUNCEMENT
Notice 2012–2, page 538.
This notice provides interim guidance under section 6050W of
the Code to payment settlement entities (as defined in Regula-
tions section 1.6050W–1(a)(4)(i)) (PSEs) that are United States
payors or United States middlemen (each as defined in Reg-
ulations section 1.6049–5(c)(5)) regarding the circumstances
under which the return of information required under Regula-
tions section 1.6050W–1(a)(1) is required with respect to a
payment to an offshore account. Treasury and the Service
intend to amend the regulations under section 6050W to re-
flect the guidance provided in this notice and Notice 2011–71,
2011–37 I.R.B. 233. PSEs may rely on the interim guidance in
this notice until the regulations are amended.
INCOME TAX
Rev. Rul. 2012–30, page 534.
Federal rates; adjusted federal rates; adjusted federal
long-term rate and the long-term exempt rate.For pur-
poses of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for October 2012.
Notice 2012–2, page 538.
This notice provides interim guidance under section 6050W of
the Code to payment settlement entities (as defined in Regula-
tions section 1.6050W–1(a)(4)(i)) (PSEs) that are United States
payors or United States middlemen (each as defined in Reg-
ulations section 1.6049–5(c)(5)) regarding the circumstances
under which the return of information required under Regula-
tions section 1.6050W–1(a)(1) is required with respect to a
payment to an offshore account. Treasury and the Service
intend to amend the regulations under section 6050W to re-
flect the guidance provided in this notice and Notice 2011–71,
2011–37 I.R.B. 233. PSEs may rely on the interim guidance in
this notice until the regulations are amended.
Rev. Proc. 2012–41, page 539.
This procedure sets forth the 2013 cost-of-living adjustments
to certain items due to inflation as required under various provi-
sions of the Code and Service guidance. This procedure does
not include the following items: the tax rate tables under sec-
tion 1 , the adoption credit under section 23, the child tax credit
under section 24, the Hope Scholarship and Lifetime Learning
Credits under section 25A, the earned income credit under sec-
tion 32, the standard deduction under section 63, the overall
limitation on itemized deductions under section 68, the adop-
tion assistance exclusion under section 137, the personal ex-
emption under section 151, the interest on education loans
under section 221, and the unified credit against estate tax for
estates of decedents under section 2010(c). Those items will
be addressed in future guidance.
(Continued on the next page)
Finding Lists begin on page ii.

EXEMPT ORGANIZATIONS
Announcement 2012–37, page 543.
The IRS has revoked its determination that American Lithuanian
Childcare Association of Chicago, IL; Angel Wings Foundation
of Orem, UT; Concord International High School, Inc., of Los
Angeles, CA; Contra Costa Amateur Cheerleading Association,
Inc., of Concord, CA; Golden Rain Foundation of Laguna Woods
of Laguna Woods, CA; Grandma’s Child Care of Cassopolis, MI;
Holy Cross Canoga Park of Canoga Park, CA; Innovation Treat-
ment Centers, Inc., of Rialto, CA; Pacific Epilepsy Society of
Puunene, HI; Play 4 Life, Inc., of New York, NY; Scruggs &
Associates Family Counseling Center, Inc., of Stafford, TX; So-
cial and Economic Rights Action Center of Gaithersburg, MD;
Social and Economic Rights Action Center of Washington, DC;
The Retired Enlisted Association Incorporated Auxiliary #47 of
Fayetteville, NC; Treasures for the Kingdom of Allen, TX; World
Health and Education Foundation of Danville, CA, qualify as or-
ganizations described in sections 501(c)(3) and 170(c)(2) of
the Code.
ESTATE TAX
Rev. Proc. 2012–41, page 539.
This procedure sets forth the 2013 cost-of-living adjustments
to certain items due to inflation as required under various provi-
sions of the Code and Service guidance. This procedure does
not include the following items: the tax rate tables under sec-
tion 1 , the adoption credit undersection 23, the child tax credit
under section 24, the Hope Scholarship and Lifetime Learning
Credits under section 25A, the earned income credit under sec-
tion 32, the standard deduction under section 63, the overall
limitation on itemized deductions under section 68, the adop-
tion assistance exclusion under section 137, the personal ex-
emption under section 151, the interest on education loans
under section 221, and the unified credit against estate tax for
estates of decedents under section 2010(c). Those items will
be addressed in future guidance.
GIFT TAX
Rev. Proc. 2012–41, page 539.
This procedure sets forth the 2013 cost-of-living adjustments
to certain items due to inflation as required under various provi-
sions of the Code and Service guidance. This procedure does
not include the following items: the tax rate tables under sec-
tion 1 , the adoption credit undersection 23, the child tax credit
under section 24, the Hope Scholarship and Lifetime Learning
Credits under section 25A, the earned income credit under sec-
tion 32, the standard deduction under section 63, the overall
limitation on itemized deductions under section 68, the adop-
tion assistance exclusion under section 137, the personal ex-
emption under section 151, the interest on education loans
under section 221, and the unified credit against estate tax for
estates of decedents under section 2010(c). Those items will
be addressed in future guidance.
EXCISE TAX
Rev. Proc. 2012–41, page 539.
This procedure sets forth the 2013 cost-of-living adjustments
to certain items due to inflation as required under various provi-
sions of the Code and Service guidance. This procedure does
not include the following items: the tax rate tables under sec-
tion 1 , the adoption credit under section 23, the child tax credit
under section 24, the Hope Scholarship and Lifetime Learning
Credits under section 25A, the earned income credit under sec-
tion 32, the standard deduction under section 63, the overall
limitation on itemized deductions under section 68, the adop-
tion assistance exclusion under section 137, the personal ex-
emption under section 151, the interest on education loans
under section 221, and the unified credit against estate tax for
estates of decedents under section 2010(c). Those items will
be addressed in future guidance.
ADMINISTRATIVE
Rev. Proc. 2012–41, page 539.
This procedure sets forth the 2013 cost-of-living adjustments
to certain items due to inflation as required under various provi-
sions of the Code and Service guidance. This procedure does
not include the following items: the tax rate tables under sec-
tion 1 , the adoption credit under section 23, the child tax credit
under section 24, the Hope Scholarship and Lifetime Learning
Credits under section 25A, the earned income credit under sec-
tion 32, the standard deduction under section 63, the overall
limitation on itemized deductions under section 68, the adop-
tion assistance exclusion under section 137, the personal ex-
emption under section 151, the interest on education loans
under section 221, and the unified credit against estate tax for
estates of decedents under section 2010(c). Those items will
be addressed in future guidance.
November 5, 20122012–45 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.
2012–45 I.R.B.November 5, 2012

November 5, 20122012–45 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 1.—Ta
xImposed
The Service pr
ovides an inflation adjustment to the
amount used to
reduce the net unearned income of a
minor child su
bject to the kiddie tax for taxable years
beginning in 2
013. See Rev. Proc. 2012-41, page
539.
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
The Service provides inflation adjustments to the
amounts used to calculate the State housing credit
ceiling used in determining the low-income housing
credit, and the per low-income unit qualified basis
amount, for calendar year 2013. See Rev. Proc.
2012-41, page 539.
Section 59.—Other
Definitions and Special
Rules for the Alternative
Minimum Tax
The Service provides an inflation adjustment to the
exemption amount used in computing the alternative
minimum tax for a minor child subject to the kiddie
tax for taxable years beginning in 2013. See Rev.
Proc. 2012-41, page 539.
Section 62.—Adjusted
Gross Income Defined
The Service provides inflation adjustments to the
amounts an eligible employer may pay in calendar
year 2013 to certain welders and heavy equipment
mechanics for rig-related expenses that are deemed
substantiated under an accountable plan if paid in ac-
cordance with Rev. Proc. 2002–41, 2002–1 C.B.
1098. See Rev. Proc. 2012-41, page 539.
Section 135.—Income
From United States Savings
Bonds Used to Pay Higher
Education Tuition and Fees
The Service provides inflation adjustments to the
limitation on the exclusion of income from United
States savings bonds for taxpayers who pay qualified
higher education expenses for taxable years begin-
ning in 2013. See Rev. Proc. 2012-41, page 539.
Section 146 .—
Volume Cap
The Service pr
ovides inflation adjustments to the
amounts used t
o determine the State ceiling for the
volume cap of p
rivate activity bonds for calendar year
2013. See Rev.
Proc. 2012-41, page 539.
Section 147.—Other
Requirements Applicable to
Certain Private Activity
Bonds
The Service provides an inflation adjustment to the
loan limit amount on agricultural bonds for first-time
farmers for calendar year 2013. See Rev. Proc. 2012-
41, page 539.
Section 148.—Arbitrage
26 C.F.R. 1.148–5: Yield and valuation of investment.
The Service provides inflation adjustments for de-
termining in the calendar year 2013 whether a bro-
ker’s commission or similar fee with respect to the
acquisition of a guaranteed investment contract or in-
vestments purchased for a yield restricted defeasance
escrow is reasonable. The Service provides an in-
flation adjustment to the computation credit deter-
mined under permission to rely on § 1.148–3(d)(4) of
the proposed Income Tax Regulations for bond years
ending in 2013. See Rev. Proc. 2012-41, page 539.
Section 213.—Medical,
Dental, etc., Expenses
The Service provides inflation adjustments to the
limitations on the amount of eligible long-term care
premiums includible in the term medical care for tax-
able years beginning in 2013. See Rev. Proc. 2012-
41, page 539.
Section 220.—Archer MSAs
The Service provides inflation adjustments to the
amounts used to determine whether a health plan is a
high deductible health plan for purposes of determin-
ing whether an individual is eligible for a deduction
for cash paid to a medical savings account for taxable
years beginning in 2013. See Rev. Proc. 2012-41,
page 539.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2012. See
Rev. Rul. 2012-30, page 534.
Section 382.—
Limitation
on Net Operati
ng Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of November 2012. See Rev.
Rul. 2012-30, page 534.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2012. See
Rev. Rul. 2012-30, page 534.
Secti
on 483.—Interest on
Cert
ain Deferred Payments
The ad
justed applicable federal short-term, mid-
term
, and long-term rates are set forth for the month
of No
vember 2012. See Rev. Rul. 2012-30, page
534.
2012–45 I.R.B.533November 5, 2012

Section 512.—Unrelated
Business Taxable Income
The Service provides an inflation adjustment to the
maximum amount of annual dues that can be paid
to certain agricultural or horticultural organizations
without any portion being treated as unrelated trade
or business income by reason of any benefits or priv-
ileges available to members for taxable years begin-
ning in 2013. See Rev. Proc. 2012-41, page 539.
Section 513.—Unrelated
Trade or Business
The Service provides an inflation adjustment to the
maximum cost of a low cost article for taxable years
beginning in 2013. Funds raised through a charity’s
distribution of low cost articles will not be treated as
unrelated business income to the charity. See Rev.
Proc. 2012-41, page 539.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2012. See
Rev. Rul. 2012-30, page 534.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 877.—Expatriation
to Avoid Tax
The Service provides an inflation adjustment to
the amount used for calendar year 2013 to determine
whether an individual’s loss of United States citizen-
ship had the avoidance of United States tax as one of
its principal purposes. See Rev. Proc. 2012-41, page
539.
Section 877A.—Tax
Responsibilities of
Expatriation
The Service provides an inflation adjustment to the
amount that reduces the amount that would be in-
cludible in the gross income of a covered expatriate
for taxable years beginning in 2013. See Rev. Proc.
2012-41, page 539.
Section 911.—Citizens or
Residents of the United
States Living Abroad
The Service provides an inflation adjustment to
the amount of foreign earned income that may be ex-
cluded from gross income for taxable years beginning
in 2013. See Rev. Proc. 2012-41, page 539.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate and the
long-term exempt rate.For purposes of
sections 382, 642, 1274, 1288, and other
sections of the Code, tables set forth the
rates for October 2012.
Rev. Rul. 2012–30
This revenue ruling provides various
prescribed rates for federal income tax
purposes for November 2012 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month
for purposes of section 1274(d) of the
Internal Revenue Code. Table 2 contains
the short-term, mid-term, and long-term
adjusted applicable federal rates (ad-
justed AFR) for the current month for
purposes of section 1288(b). Table 3 sets
forth the adjusted federal long-term rate
and the long-term tax-exempt rate de-
scribed in section 382(f). Table 4 contains
the appropriate percentages for deter-
mining the low-income housing credit
described in section 42(b)(1) for build-
ings placed in service during the current
month. However, under section 42(b)(2),
the applicable percentage for non-feder-
ally subsidized new buildings placed in
service after July 30, 2008, and before
December 31, 2013, shall not be less than
9%. Finally, Table 5 contains the federal
rate for determining the present value of
an annuity, an interest for life or for a term
of years, or a remainder or a reversionary
interest for purposes of section 7520.
November 5, 20125342012–45 I.R.B.

REV. RUL. 2012–30 TABLE 1
Applicable Federal Rates(AFR) for November 2012
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.22%.22%.22%.22%
110% AFR.24%.24%.24%.24%
120% AFR.26%.26%.26%.26%
130% AFR.29%.29%.29%.29%
Mid-term
AFR.89%.89%.89%.89%
110% AFR.98%.98%.98%.98%
120% AFR1.07%1.07%1.07%1.07%
130% AFR1.16%1.16%1.16%1.16%
150% AFR
1.34%1.34%1.34%1.34%
175% AFR1.57%1.56%1.56%1.55%
Long-term
AFR2.40%2.39%2.38%2.38%
110% AFR
2.65%
2.63%2.62%2.62%
120% AFR2.89%2.87%2.86%
2.85%
130% AFR3.13%3.11%3.10%3.09%
REV. RUL. 20
12–30 TABLE 2
Adjusted AFR for November 2012
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR.24%.24%.24%.24%
Mid-term adjusted AFR.98%.98%.98%.98%
Long-ter
m
adjuste
dAFR
2.84%2.82%2.81%2.80%
REV. RUL. 2012–30 TABLE 3
Rates Under Section 382 for November 2012
Adjuste
d federal long-term rate for the current month
2.84%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)2.87%
2012–45 I.R.B.535November 5, 2012

REV. RUL. 2012–30 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for November 2012
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.38%
Appropriate percentage for the 30% present value low-income housing credit3.16%
REV. RUL. 2012–30 TABLE 5
Rate Under Sec
tion 7520 for November 2012
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest1.0%
Section 1288.
—Treatment
of Original Is
sue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 2032A.—Valuation
of Certain Farm, etc.,
Real Property
The Service provides an inflation adjustment to the
maximum amount by which the value of certain farm
and other qualified real property included in a dece-
dent’s gross estate may be decreased for purposes of
valuing the estate of a decedent dying in calendar year
2013. See Rev. Proc. 2012-41, page 539.
Section 2503.—Taxable
Gifts
The Service provides an inflation adjustment to the
amount of gifts that may be made to a person in a
calendar year without including the amount in taxable
gifts for calendar year 2013. See Rev. Proc. 2012-41,
page 539.
Section 2
523.—Gift to
Spouse
The Servi
ce provides an inflation adjustment to the
amount of
gifts that may be made in a calendar year
to a spou
se who is not a citizen of the United States
without
including the amount in taxable gifts for cal-
endar ye
ar 2013. See Rev. Proc. 2012-41, page 539.
Section 4161.—Imposition
of Tax
The Service provides an inflation adjustment to the
amount of excise tax imposed for calendar year 2013
on the first sale by a manufacturer, producer, or im-
porter of any shaft of a type used in the manufacture
of certain arrows. See Rev. Proc. 2012-41, page 539.
Section 4261.—Passenger
Air Transportation
Excise Ta
x
The Servi
ce provides inflation adjustments for ex-
cise taxe
s on domestic and international passenger air
transpor
tation for calendar year 2013. See Rev. Proc.
2012-41,
page 539.
Section 6033.—Returns by
Exempt O
rganizations
The Serv
ice provides an inflation adjustment to
the amou
nt of dues certain exempt organizations with
nondedu
ctible lobbying expenditures can charge and
still be
excepted from reportingrequirements for tax-
able yea
rs beginning in 2013. See Rev. Proc. 2012-
41, pag
e 539.
Section 6039F.—Notice of
Large Gifts Received From
Foreign Persons
The Service provides an inflation adjustment to the
amount of gifts received in a taxable year from for-
eign persons that triggers a reporting requirement for
a United States person for taxable years beginning in
2013. See Rev. Proc. 2012-41, page 539.
Section 6323.—Validity
and Priority Against
Certain Persons
The Service provides inflation adjustments for cal-
endar year 2013 to (1) the maximum amount of a ca-
sual sale of personal property below which a federal
tax lien will not be valid against a purchaser of the
property, and (2) the maximum amount of a contract
for the repair or improvement of certain residential
property at or below which a federal tax lien will not
be valid against a mechanic’s lienor. See Rev. Proc.
2012-41, page 539.
Section 6334.—Property
Exempt From Levy
The Service provides inflation adjustments to the
value of certain property exempt from levy (fuel, pro-
visions, furniture, household personal effects, arms
for personal use, livestock, poultry, and books and
tools of a trade, business, or profession) for calendar
year 2013. See Rev. Proc. 2012-41, page 539.
Section 6601.—Interest
on Underpayment,
Nonpaym
ent or Extension
of Time for Payment, of Tax
The Service provides an inflation adjustment to
the amount used to determine the amount of interest
charged on a certain portion of the estate tax payable
in installments for the estate of a decedent dying in
calendar year 2013. See Rev. Proc. 2012-41, page
539.
Section 7430.—Awarding
of Costs and Certain Fees
The Service provides an inflation adjustment to the
hourly limit on attorney fees incurred in calendar year
2013 that may be awarded in a judgment or settlement
November 5, 20125362012–45 I.R.B.

of an administrative or judicial proceeding concern-
ing the determination, collection, or refund of tax, in-
terest, or penalty. See Rev. Proc. 2012-41, page 539.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
Section 7702B.—Treatment
of Qualified Long-Term
Care Insurance
The Service provides an inflation adjustment to the
stated dollar amount for calendar year 2013 of theper
diemlimitation regarding periodic payments received
under a qualified long-term care insurance contract
or periodic payments received under a life insurance
contract that are treated as paid by reason of the death
of a chronically ill individual. See Rev. Proc. 2012-
41, page 539.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2012. See Rev. Rul. 2012-30, page
534.
2012–45 I.R.B.537November 5, 2012

Part III. Administrative, Procedural, and Miscellaneous
Documentation Requirements
Under Section 6050W
Notice 2012–2
PURPOSE
This notice provides interim guidance
to payment settlement entities (as de-
fined in § 1.6050W–1(a)(4)(i)) (PSEs)
that are United States payors or United
States middlemen (each as defined in
§ 1.6049–5(c)(5)) (U.S. payors) regard-
ing the circumstances under which the
return of information required under
§ 1.6050W–1(a)(1) is required with re-
spect to a payment to an account main-
tained outside the United States. This
notice supplements, but does not mod-
ify or supersede, the guidance provided
in Notice 2011–71, 2011–37 I.R.B. 233.
The Department of the Treasury (Treasury
Department) and the Internal Revenue
Service (IRS) intend to amend the reg-
ulations under section 6050W to reflect
the guidance provided in this notice and
Notice 2011–71. PSEs may rely on the
interim guidance in this notice until the
regulations are amended.
BACKGROUND
Section 6050W of the Internal Revenue
Code was added by section 3091 of the
Housing Assistance Tax Act of 2008, Div.
C of Pub. L. No. 110–289, 122 Stat.
2653 (the Act), and requires information
returns to be made by certain payors with
respect to payments made to a participat-
ing payee (generally meaning a merchant
that accepts a payment card or payment
from a third party settlement organization)
in settlement of payment card transactions
and third party payment network transac-
tions. Section 6050W(d)(1)(B) provides
that, except as provided by the Secretary
in regulations or other guidance, the term
participating payee does not include any
person with a foreign address. The final
regulations prescribe the circumstances in
which a PSE is required to report payments
made to a participating payee that has a for-
eign address. Specifically, the final regu-
lations provide that a PSE that is not a U.S.
payor is not required to report payments
made to a participating payee that does not
have a U.S. address as long as the PSE nei-
ther knows nor has reason to know that the
payee is a United States person (U.S. per-
son). If the participating payee has any
U.S. address, a PSE may treat the partic-
ipating payee as a foreign person only if
the PSE has in its files documentation upon
which the PSE may rely to treat the pay-
ment as made to a foreign person in accor-
dance with § 1.1441–1(e)(1)(ii).
The final regulations also provide
that a PSE that is a U.S. payor is not
required to report payments to payees
with a foreign address as long as, prior
to payment, the payee has provided the
payor with documentation upon which
the payor may rely to treat the payment
as made to a foreign person in accor-
dance with § 1.1441–1(e)(1)(ii). In ad-
dition, the final regulations provide a
presumption under which a PSE that is
a U.S. payor making a payment outside
the United States (within the meaning
of § 1.6049–5(e)) to an offshore account
(as defined in § 1.6049–5(c)(1)) need not
report payments to a participating payee
with only a foreign address if the name
of the participating payee indicates that
it is a foreignper secorporation listed in
§ 301.7701–2(b)(8)(i) and the PSE neither
knows nor has reason to know that the par-
ticipating payee is a U.S. person. The final
regulations also provide a grace period
after account opening to collect documen-
tation by applying the grace period rules
of § 1.6049–5(d)(2)(ii) if the participating
payee has only a foreign address.
The final regulations apply to returns
for calendar years beginning after Decem-
ber 31, 2010. The final regulations also
provide a transition rule, which provides
that, for payments made pursuant to con-
tractual obligationsentered into before
January 1, 2011, a PSE that is a U.S. payor
is not required to report payments made
to a participating payee with a foreign
address as long as the U.S. payor neither
knows nor has reason to know that the
payee is a U.S. person. For this purpose,
a renewal of such a contractual obligation
will not result in a new contractual obliga-
tion unless there is a material modification
of the contractual obligation.
Notice 2011–71 states that the Trea-
sury Department and the IRS intend
to amend the regulations under section
6050W to provide that a PSE that is a
U.S. payor will only be required to make
the return of information required under
§ 1.6050W–1(a)(1) with respect to a pay-
ment made outside the United States to an
offshore account if any of the following
applies: (i) there is a U.S. address associ-
ated with the participating payee (whether
a residence address or correspondence
address); (ii) the PSE has standing in-
structions to direct the payment to a bank
account maintained in the United States;
(iii) the participating payee submits for
payment in U.S. dollars; or (iv) the PSE
knows or has reason to know that the par-
ticipating payee is a U.S. person.
DISCUSSION
The Treasury Department and the IRS
have received a comment expressing un-
certainty about the circumstances under
which a payment is considered made
outside the United States to an offshore
account for purposes of section 6050W. In
response, the Treasury Department and the
IRS intend to amend the regulations under
section 6050W to provide an alternative
method for a PSE to determine whether
it must make the return of information
required under § 1.6050W–1(a)(1). The
alternative method will apply only to a
PSE that: (i) is a U.S. payor; (ii) makes
a payment to an account maintained out-
side the United States by the PSE or, if
the PSE does not maintain an account
of the participating payee, makes a pay-
ment to an account maintained outside
the United States by another financial in-
stitution (in eithercase without regard to
whether the payment is made outside the
United States); and (iii) has reasonably
determined, based on all the informa-
tion obtained or reviewed in connection
with the establishment or maintenance
of the contractual relationship with the
participating payee (including informa-
tionrequiredtobeobtainedorreviewed
under procedures required to be estab-
lished under and compliant with 31 CFR
§ 103.121(b)), that the participating payee
is doing business outside the United States.
In such case, the PSE will only be re-
quired to make the return of information
required under § 1.6050W–1(a)(1) if any
November 5, 20125382012–45 I.R.B.

of the following applies: (i) there is a U.S.
address associated with the participating
payee (whether a residence address or
correspondence address); (ii) the PSE has
standing instructions to direct the pay-
ment to a bank account maintained in
the United States; (iii) the participating
payee submits for payment in U.S. dollars;
or (iv) the PSE knows or has reason to
know that the participating payee is a U.S.
person. Notwithstanding the preceding
sentence, a PSE will not be required to
make the return of information required
under § 1.6050W–1(a)(1) if the PSE ob-
tains from the participating payee a valid
Form W–8 or documentary evidence es-
tablishing the payee’s non-U.S. status and
the PSE does not know that the payee is
a U.S. person. For purposes of section
6050W, an account is maintained outside
the United States if it is maintained at an
office or branch of a financial institution at
any location outside the United States and
outside the territories of the United States.
DRAFTING INFORMATION
The principal author of this notice is
Danielle Nishida of the Office of Associate
Chief Counsel (International). For further
information regarding this notice, please
contact Ms. Nishida at (202) 622–5399
(not a toll-free call).
26 CFR 601.602: Tax forms and instructions.
(Also Part I, §§ 1, 42, 59, 62, 135, 146, 147, 148, 213,
220, 512, 513, 877, 877A, 911, 2032A, 2503, 2523,
4161, 4261, 6033, 6039F, 6323, 6334, 6601, 7430,
7702B; 1.148–5.)
Rev. Proc. 2012–41
Table of Contents
SECTION 1. PURPOSE
SECTION 2. CHANGES
SECTION 3. 2013 ADJUSTED ITEMS
C
odeSection
.01 Unearned Income of Minor Children Taxedas if Parent’s Income (“Kiddie Tax”)1(g)
.02 Rehabilitation Expenditures Treated as Separate New Building42(e)
.03 Low-Income Housing Credit42(h)
.04 Alternative Minimum Tax Exemption for a Child Subject to the “Kiddie Tax”
59(j)
.05 Transportation Mainline Pipeline ConstructionIndustry Optional Expense Substantiation Rules for
Payments to Employees under Accountable Plans
62(c)
.06 Income from United States Savings Bonds for Taxpayers Who Pay Qualified Higher Education Expenses
135
.07 Private Activity Bonds Volume Cap146(d)
.08 Loan Limits on Agricultural Bonds147(c)(2)
.09 General Arbitrage Rebate Rules148(f)
.10 Safe Harbor Rules for Broker Commissions on Guaranteed Investment Contracts or Investments
Purchased for a Yield Restricted Defeasance Escrow
148
.11 Eligible Long-Term Care Premiums213(d)(10)
.12 Medical Savings Accounts220
.13 Treatment of Dues Paid to Agricultural or Horticultural Organizations
512(d)
.14 Insubstantial Benefit Limitations for Contributions Associated WithCharitable Fund-Raising Campaigns
513(h)
.15ExpatriationtoAvoidTax
877
.16 Tax Responsibilities of Expatriation877A
.17 Foreign Earned Income Exclusion911
.18 Valuation of Qualified Real Property in Decedent’s Gross Estate2032A
.19 Annual Exclusion for Gifts
2503; 2523
.20 Tax on Arrow Shafts4161
.21 Passenger Air Transportation Excise Tax4261
.22 Reporting Exception for Certain Exempt Organizations with Nondeductible Lobbying Expenditures6033(e)(3)
2012–45 I.R.B.539November 5, 2012

.23 Notice of Large Gifts Received from Foreign Persons6039F
.24 Persons Against Whom a Federal Tax Lien Is Not Valid6323
.25 Property Exempt from Levy
6334
.26 Interest on a Certain Portion of the Estate Tax Payable in Installments6601(j)
.27 Attorney Fee Awards7430
.28 Periodic Payments Received under Qualified Long-Term Care Insurance Contracts or under Certain
Life Insurance Contracts
7702B(d)
SECTION 4. EFFECTIVE DATE
SECTION 5. DRAFTING INFORMATION
SECTION 1. PURPOSE
This r
evenue procedure sets forth infla-
tion-
adjusted items for 2013.
SECTI
ON 2. CHANGES
This revenue procedure does not in-
clude the following items: the tax rate
tables under § 1 of the Internal Revenue
Code (Code), the adoption credit under
§ 23, the child tax credit under § 24, the
Hope Scholarship and Lifetime Learning
Credits under § 25A, the earned income
credit under § 32, the standard deduc-
tion under § 63, the overall limitation on
itemized deductions under § 68, the qual-
ified transportation fringe benefit under
§ 132(f), the adoption assistance exclusion
under § 137, the personal exemption un-
der § 151, the election to expense certain
depreciable assets under § 179, the interest
on education loans under § 221, and the
unified credit against estate tax for estates
of decedents under § 2010(c). Those items
will be addressed in future guidance.
SECTION 3. 2013 ADJUSTED ITEMS
.01Unearned Income of Minor
Children Taxed as if Parent’s Income
(the “Kiddie Tax”). For taxable years
beginning in 2013, the amount in
§ 1(g)(4)(A)(ii)(I), which is used to reduce
the net unearned income reported on the
child’s return that is subject to the “kid-
die tax,” is $1,000. This $1,000 amount
is the same as the amount provided in
§ 63(c)(5)(A), as adjusted for inflation.
The same $1,000 amount is used for pur-
poses of § 1(g)(7) (that is, to determine
whether a parent may elect to include a
child’s gross income in the parent’s gross
income and to calculate the “kiddie tax”).
For example, one of the requirements for
the parental election is that a child’s gross
income is more than the amount refer-
enced in § 1(g)(4)(A)(ii)(I) but less than
10 times that amount; thus, a child’s gross
income for 2013 must be more than $1,000
but less than $10,000.
.02Rehabilitation Expenditures
Treated as Separate New Building.For
calendar year 2013, the per low-in-
come unit qualified basis amount under
§ 42(e)(3)(A)(ii)(II) is $6,400.
.03Low-Income Housing Credit.For
calendar year 2013, the amount used un-
der § 42(h)(3)(C)(ii) to calculate the State
housing credit ceiling for the low-income
housing credit is the greater of (1) $2.25
multiplied by the State population, or (2)
$2,590,000.
.04Alternative Minimum Tax Exemp-
tion for a Child Subject to the “Kiddie
Tax.”For taxable years beginning in 2013,
for a child to whom the § 1(g) “kiddie tax”
applies, the exemption amount under §§ 55
and 59(j) for purposes of the alternative
minimum tax under § 55 may not exceed
the sum of (1) the child’s earned income
for the taxable year, plus (2) $7,150.
.05Transportation Mainline Pipeline
Construction Industry Optional Expense
Substantiation Rules for Payments to Em-
ployees under Accountable Plans.For
calendar year 2013, an eligible employer
may pay certain welders and heavy equip-
ment mechanics an amount of up to $17
per hour for rig-related expenses that is
deemed substantiated under an account-
able plan if paid in accordance with Rev.
Proc. 2002–41, 2002–1 C.B. 1098. If the
employer provides fuel or otherwise reim-
burses fuel expenses, up to $10 per hour
is deemed substantiated if paid under Rev.
Proc. 2002–41.
.06Income from United States Savings
Bonds for Taxpayers Who Pay Qualified
Higher Education Expenses. For taxable
years beginning in 2013, the exclusion un-
der § 135, regarding income from United
States savings bonds for taxpayers who
pay qualified higher education expenses,
begins to phase out for modified adjusted
gross income above $112,050 for joint
returns and $74,700 for other returns.
The exclusion is completely phased out
for modified adjusted gross income of
$142,050 or more for joint returns and
$89,700 or more for other returns.
.07Private Activity Bonds Volume Cap.
For calendar year 2013, the amounts used
under § 146(d)(1) to calculate the State
ceiling for the volume cap for private
activity bonds is the greater of (1) $95
multiplied by the State population, or (2)
$291,875,000.
.08Loan Limits on Agricultural Bonds.
For calendar year 2013, the loan limit
amount on agricultural bonds under
§ 147(c)(2)(A) for first-time farmers is
$501,100.
.09General Arbitrage Rebate Rules.
For bond years ending in 2013, the
amount of the computation credit deter-
mined under the permission to rely on
§ 1.148–3(d)(4) of the proposed Income
Tax Regulations is $1,590.
.10Safe Harbor Rules for Broker
Commissions on Guaranteed Invest-
ment Contracts or Investments Purchased
for a Yield Restricted Defeasance Es-
crow. For calendar year 2013, under
§ 1.148–5(e)(2)(iii)(B)(1), a broker’s com-
mission or similar feefor the acquisition
of a guaranteed investment contract or in-
vestments purchased for a yield restricted
defeasance escrow is reasonable if (1) the
amount of the fee that the issuer treats as
a qualified administrative cost does not
exceed the lesser of (A) $37,000, and (B)
0.2 percent of the computational base (as
defined in § 1.148–5(e)(2)(iii)(B)(2)) or,
if more, $4,000; and (2) the issuer does
November 5, 20125402012–45 I.R.B.

not treat more than $106,000 in brokers’
commissions or similar fees as qualified
administrative costs for all guaranteed
investment contracts and investments for
yield restricted defeasance escrows pur-
chased with gross proceeds of the issue.
.11Eligible Long-Term Care Premi-
ums. For taxable years beginning in 2013,
the limitations under § 213(d)(10), re-
garding eligible long-term care premiums
includible in the term “medical care,” are
as follows:
A
ttainedAgeBeforetheCloseoftheTaxableYearLimitationonPremiums
40 or less
$360
More than 40 but not more than 50
$680
More than 50 but not more than 60
$1,360
More than 60 but not more than 70
$3,640
More than 70
$4,550
.12Medical Savings Accounts.
(1)Self-only coverage. For taxable
years beginning in 2013, the term “high
deductible health plan” as defined in
§ 220(c)(2)(A) means,for self-only cov-
erage, a health plan that has an annual
deductible that is not less than $2,150 and
not more than $3,200, and under which the
annual out-of-pocket expenses required
to be paid (other than for premiums) for
covered benefits do not exceed $4,300.
(2)Family coverage. For taxable years
beginning in 2013, the term “high de-
ductible health plan” means, for family
coverage, a health plan that has an annual
deductible that is not less than $4,300 and
not more than $6,450, and under which the
annual out-of-pocket expenses required
to be paid (other than for premiums) for
covered benefits do not exceed $7,850.
.13Treatment of Dues Paid to Agricul-
tural or Horticultural Organizations.For
taxable years beginning in 2013, the limi-
tation under § 512(d)(1), regarding the ex-
emption of annual dues required to be paid
by a member to an agricultural or horticul-
tural organization, is $155.
.14Insubstantial Benefit Limitations
for Contributions Associated with Chari-
table Fund-Raising Campaigns.
(1)Low cost article. For taxable years
beginning in 2013, for purposes of defin-
ing the term “unrelated trade or business”
for certain exempt organizations under
§ 513(h)(2), “low cost articles” are articles
costing $10.20 or less.
(2)Other insubstantial benefits.For
taxable years beginning in 2013, under
§ 170, the $5, $25, and $50 guidelines in
section 3 of Rev. Proc. 90–12, 1990–1
C.B. 471 (as amplified by Rev. Proc.
92–49, 1992–1 C.B. 987, and modified by
Rev. Proc. 92–102, 1992–2 C.B. 579), for
the value of insubstantial benefits that may
be received by a donor in return for a con-
tribution, without causing the contribution
to fail to be fully deductible, are $10.20,
$51, and $102, respectively.
.15Expatriation to Avoid Tax.For
calendar year 2013, an individual with
“average annual netincome tax” of more
than $155,000 for the five taxable years
ending before the date of the loss of United
States citizenship under § 877(a)(2)(A)
is a covered expatriate for purposes of
§ 877A(g)(1).
.16Tax Responsibilities of Expatria-
tion. For taxable years beginning in 2013,
the amount that would be includible in the
gross income of a covered expatriate by
reason of § 877A(a)(1) is reduced (but not
below zero) by $668,000.
.17Foreign Earned Income Exclusion.
For taxable years beginning in 2013, the
foreign earned income exclusion amount
under § 911(b)(2)(D)(i) is $97,600.
.18Valuation of Qualified Real Prop-
erty in Decedent’s Gross Estate.Foran
estate of a decedent dying in calendar year
2013, if the executor elects to use the spe-
cial use valuation method under § 2032A
for qualified real property, the aggregate
decrease in the value of qualified real prop-
erty resulting from electing to use § 2032A
for purposes of the estate tax cannot ex-
ceed $1,070,000.
.19Annual Exclusion for Gifts.
(1) For calendar year 2013, the first
$14,000 of gifts to any person (other than
gifts of future interests in property) are
not included in the total amount of taxable
gifts under § 2503 made during that year.
(2) For calendar year 2013, the first
$143,000 of gifts to a spouse who is not
a citizen of the United States (other than
gifts of future interests in property) are
not included in the total amount of taxable
gifts under §§ 2503 and 2523(i)(2) made
during that year.
.20Tax on Arrow Shafts. For calen-
dar year 2013, the tax imposed under
§ 4161(b)(2)(A) on the first sale by the
manufacturer, producer, or importer of any
shaft of a type used in the manufacture of
certain arrows is $0.48 per shaft.
.21Passenger Air Transportation Ex-
cise Tax. For calendar year 2013, the tax
under § 4261(b)(1) on the amount paid for
each domestic segment of taxable air trans-
portation is $3.90. For calendar year 2013,
the tax under § 4261(c)(1) on any amount
paid (whether within or without the United
States) for any international air transporta-
tion, if the transportation begins or ends in
the United States, generally is $17.20. Un-
der § 4261(c)(3), however, a lower amount
applies under § 4261(c)(1) to a domestic
segment beginning or ending in Alaska or
Hawaii, and the tax applies only to depar-
tures. For calendar year 2013, the rate is
$8.60.
.22Reporting Exception for Certain
Exempt Organizations with Nondeductible
Lobbying Expenditures. For taxable years
beginning in 2013, the annual per per-
son, family, or entity dues limitation to
qualify for the reporting exception under
§ 6033(e)(3) (and section 5.05 of Rev.
Proc. 98–19, 1998–1 C.B. 547), regarding
certain exempt organizations with nonde-
ductible lobbying expenditures, is $108 or
less.
.23Notice of Large Gifts Received from
Foreign Persons. For taxable years begin-
ning in 2013, § 6039F authorizes the Trea-
sury Department and the Internal Revenue
Service to require recipients of gifts from
certain foreign persons to report these gifts
if the aggregate value of gifts received in
the taxable year exceeds $15,102.
.24Persons Against Whom a Federal
Tax Lien Is Not Valid. For calendar year
2013, a federal tax lien is not valid against
(1) certain purchasers under § 6323(b)(4)
2012–45 I.R.B.541November 5, 2012

who purchased personal property in a
casual sale for less than $1,470, or (2)
a mechanic’s lienor under § 6323(b)(7)
who repaired or improved certain residen-
tial property if the contract price with the
owner is not more than $7,350.
.25Property Exempt from Levy.For
calendar year 2013, the value of property
exempt from levy under§ 6334(a)(2) (fuel,
provisions, furniture, and other household
personal effects, as well as arms for per-
sonal use, livestock, and poultry) cannot
exceed $8,790. The value of property ex-
empt from levy under § 6334(a)(3) (books
and tools necessary for the trade, business,
or profession of the taxpayer) cannot ex-
ceed $4,400.
.26InterestonaCertainPortionofthe
Estate Tax Payable in Installments.Foran
estate of a decedent dying in calendar year
2013, the dollar amount used to determine
the “2-percent portion” (for purposes of
calculating interest under § 6601(j)) of the
estate tax extended as provided in § 6166
is $1,430,000.
.27Attorney Fee Awards. For fees
incurred in calendar year 2013, the
attorney fee award limitation under
§ 7430(c)(1)(B)(iii) is $190 per hour.
.28Periodic Payments Received un-
der Qualified Long-Term Care Insurance
Contracts or under Certain Life Insur-
ance Contracts. For calendar year 2013,
the stated dollar amount of theper diem
limitation under § 7702B(d)(4), regarding
periodic payments received under a qual-
ified long-term care insurance contract or
periodic payments received under a life
insurance contract that are treated as paid
by reason of the death of a chronically ill
individual, is $320.
SECTION 4. EFFECTIVE DATE
.01General Rule. Except as provided
in section 4.02, this revenue procedure ap-
plies to taxable years beginning in 2013.
.02Calendar Year Rule.Thisrev-
enue procedure applies to transactions or
events occurring in calendar year 2013
for purposes of sections 3.02 (rehabil-
itation expenditures treated as separate
new building), 3.03 (low-income hous-
ing credit), 3.05 (transportation mainline
pipeline construction industry optional
expense substantiation rules for payments
to employees under accountable plans),
3.07 (private activity bonds volume cap),
3.08 (loan limits on agricultural bonds),
3.09 (general arbitrage rebate rules), 3.10
(safe harbor rules for broker commissions
on guaranteed investment contracts or in-
vestments purchased for a yield restricted
defeasance escrow), 3.15 (expatriation to
avoid tax), 3.18 (valuation of qualified
real property in decedent’s gross estate),
3.19 (annual exclusion for gifts), 3.20 (tax
on arrow shafts), 3.21 (passenger air trans-
portation excise tax), 3.24 (persons against
whom a federal tax lien is not valid), 3.25
(property exempt from levy), 3.26 (inter-
est on a certain portion of the estate tax
payable in installments), 3.27 (attorney
fee awards), and 3.28(periodic payments
received under qualified long-term care
insurance contracts or under certain life
insurance contracts).
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue
procedure is William Ruane of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding this revenue procedure, contact
Mr. Ruane at (202) 622–4920 (not a
toll-free call).
November 5, 20125422012–45 I.R.B.

Part IV. Items o
fGeneralInterest
Deletions Fro
m Cumulative
List of Organi
zations
Contribution
stoWhich
are Deductib
le Under Section
170 of the Cod
e
Announcement
2012–37
The Internal Rev
enue Service has re-
voked its determ
ination that the organi-
zations listed b
elow qualify as organiza-
tions described
in sections 501(c)(3) and
170(c)(2)ofth
e Internal Revenue Code of
1986.
Generally, the
Service will not disallow
deductions for
contributions made to a
listed organiz
ation on or before the date
of announcemen
t in the Internal Revenue
Bulletin that
an organization no longer
qualifies. Ho
wever, the Service is not
precluded fro
m disallowing a deduction
for any contri
butions made after an or-
ganization c
eases to qualify under section
170(c)(2) if
the organization has not timely
filed a suit f
or declaratory judgment under
section 7428
and if the contributor (1) had
knowledge o
f the revocation of the ruling
or determin
ation letter, (2) was aware that
such revoca
tion was imminent, or (3) was
in part resp
onsible for or was aware of the
activities
or omissions of the organization
that brough
t about this revocation.
If on the oth
er hand a suit for declara-
tory judgm
ent has been timely filed,
contribut
ions from individuals and orga-
nizations des
cribed in section 170(c)(2)
that are other
wise allowable will continue
to be deductib
le. Protection under sec-
tion 7428(c) w
ould begin on November 5,
2012, and woul
d end on the date the court
first determ
ines that the organization is
not describe
d in section 170(c)(2) as more
particularl
ysetforthinsection7428(c)(1).
For individu
al contributors, the maximum
deduction p
rotected is $1,000, with a hus-
band and wif
e treated as one contributor.
This benefi
t is not extended to any indi-
vidual, in w
hole or in part, for the acts or
omissions
of the organization that were
the basis f
or revocation.
American L
ithuanian Childcare
Associati
on
Chicago, I
L
Angel Wing
s Foundation
Orem, UT
Concord In
ternational High School, Inc.
Los Angele
s, CA
Contra Cos
ta Amateur Cheerleading
Associati
on, Inc.
Concord, C
A
Golden Rai
n Foundation of Laguna
Woods
Laguna Woo
ds, CA
Grandma’s
Child Care
Cassopoli
s, MI
Holy Cross Cano
ga Park
Canoga Park, C
A
Innovation Tre
atment Centers, Inc.
Rialto, CA
Pacific Epilep
sy Society
Puunene, HI
Play4Life,Inc
.
New York, NY
Scruggs & Assoc
iates Family Counseling
Center, Inc.
Stafford, TX
Social and Econ
omic Rights Action
Center
Gaithersburg
,MD
Social and Eco
nomic Rights Action
Center
Washington, D
C
The Retired En
listed Association
Incorporated
Auxiliary #47
Fayetteville
,NC
Treasures for
the Kingdom
Allen, TX
World Health a
nd Education Foundation
Danville, CA
2012–45 I.R.B.543November 5, 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.
November 5, 2012i2012–45 I.R.B.

Numerical Finding List
1
Bulletins 2012–27 through 2012–45
Announcements:
2012-26, 2012-27 I.R.B.8
2012-27, 2012-27 I.R.B.10
2012-28, 2012-27 I.R.B.10
2012-29, 2012-42 I.R.B.500
2012-30, 2012-34 I.R.B.314
2012-31, 2012-34 I.R.B.315
2012-32, 2012-35 I.R.B.325
2012-33, 2012-35 I.R.B.325
2012-34, 2012-36 I.R.B.334
2012-35, 2012-38 I.R.B.356
2012-37, 2012-45 I.R.B.543
2012-38, 2012-43 I.R.B.527
2012-41, 2012-44 I.R.B.532
Notices:
2012-2, 2012-45 I.R.B.538
2012-39, 2012-31 I.R.B.95
2012-44, 2012-28 I.R.B.45
2012-45, 2012-29 I.R.B.59
2012-46, 2012-30 I.R.B.86
2012-47, 2012-31 I.R.B.98
2012-48, 2012-31 I.R.B.102
2012-49, 2012-31 I.R.B.119
2012-50, 2012-31 I.R.B.121
2012-51, 2012-33 I.R.B.150
2012-52, 2012-35 I.R.B.317
2012-53, 2012-35 I.R.B.317
2012-55, 2012-36 I.R.B.332
2012-56, 2012-39 I.R.B.370
2012-57, 2012-40 I.R.B.424
2012-58, 2012-41 I.R.B.436
2012-59, 2012-41 I.R.B.443
2012-60, 2012-41 I.R.B.445
2012-61, 2012-42 I.R.B.479
2012-62, 2012-42 I.R.B.489
2012-63, 2012-42 I.R.B.496
2012-64, 2012-44 I.R.B.528
Proposed Regulations:
REG-126770-06, 2012-38 I.R.B.347
REG-138367-06, 2012-40 I.R.B.426
REG-101812-07, 2012-34 I.R.B.311
REG-134042-07, 2012-27 I.R.B.5
REG-140668-07, 2012-43 I.R.B.501
REG-153627-08, 2012-29 I.R.B.60
REG-136491-09, 2012-35 I.R.B.321
REG-138489-09, 2012-38 I.R.B.355
REG-125570-11, 2012-30 I.R.B.93
REG-130266-11, 2012-32 I.R.B.126
REG-134935-11, 2012-29 I.R.B.64
REG-141832-11, 2012-28 I.R.B.54
Proposed Regulations— Continued:
REG-107889-12, 2012-28 I.R.B.53
REG-113738-12, 2012-29 I.R.B.66
Revenue Procedures:
2012-28, 2012-27 I.R.B.4
2012-29, 2012-28 I.R.B.49
2012-30, 2012-33 I.R.B.165
2012-31, 2012-33 I.R.B.256
2012-32, 2012-34 I.R.B.267
2012-33, 2012-34 I.R.B.272
2012-34, 2012-34 I.R.B.280
2012-35, 2012-37 I.R.B.341
2012-36, 2012-39 I.R.B.374
2012-37, 2012-41 I.R.B.449
2012-39, 2012-41 I.R.B.470
2012-40, 2012-40 I.R.B.424
2012-41, 2012-45 I.R.B.539
Revenue Rulings:
2012-19, 2012-28 I.R.B.16
2012-20, 2012-27 I.R.B.1
2012-21, 2012-32 I.R.B.123
2012-23, 2012-39 I.R.B.359
2012-24, 2012-36 I.R.B.329
2012-25, 2012-37 I.R.B.337
2012-26, 2012-39 I.R.B.358
2012-27, 2012-41 I.R.B.435
2012-28, 2012-42 I.R.B.476
2012-29, 2012-42 I.R.B.475
2012-30, 2012-45 I.R.B.534
Treasury Decisions:
9591, 2012-28 I.R.B.32
9592, 2012-28 I.R.B.41
9593, 2012-28 I.R.B.17
9594, 2012-29 I.R.B.57
9595, 2012-30 I.R.B.71
9596, 2012-30 I.R.B.84
9597, 2012-34 I.R.B.258
9598, 2012-38 I.R.B.343
9599, 2012-40 I.R.B.417
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2012–1 through 2012–26 is in Internal Revenue Bulletin
2012–26, dated June 25, 2012.
2012–45 I.R.B.iiNovember 5, 2012

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2012–27 through 2012–45
Announcements:
83-196
Superseded by
Rev. Proc. 2012-31, 2012-33 I.R.B.256
85-141
Superseded by
Rev. Proc. 2012-31, 2012-33 I.R.B.256
2008-105
Modified and superseded by
Ann. 2012-34, 2012-36 I.R.B.334
2012-29
Corrected by
Ann. 2012-41, 2012-44 I.R.B.532
2012-38
Corrected by
Ann. 2012-41, 2012-44 I.R.B.532
Notices:
2009-24
Amplified by
Notice 2012-51, 2012-33 I.R.B.150
2011-81
Superseded by
Notice 2012-63, 2012-42 I.R.B.496
2012-51
Amplified by
Notice 2012-51, 2012-33 I.R.B.150
Proposed Regulations:
REG-100276-97
Withdrawn by
Ann. 2012-27, 2012-27 I.R.B.10
REG-130266-11
Hearing scheduled by
Ann. 2012-38, 2012-43 I.R.B.527
Ann. 2012-29, 2012-42 I.R.B.500
Hearing rescheduled by
Ann. 2012-41, 2012-44 I.R.B.532
Revenue Procedures:
94-22
Modified and superseded by
Rev. Proc. 2012-35, 2012-37 I.R.B.341
95-15
Superseded by
Rev. Proc. 2012-31, 2012-33 I.R.B.256
97-27
Modified by
Rev. Proc. 2012-39, 2012-41 I.R.B.470
Revenue Procedures— Continued:
98-32
Modified and superseded by
Rev. Proc. 2012-33, 2012-34 I.R.B.272
2007-38
Modified and superseded by
Rev. Proc. 2012-32, 2012-34 I.R.B.267
2011-14
Clarified and modified by
Rev. Proc. 2012-39, 2012-41 I.R.B.470
2011-40
Superseded by
Rev. Proc. 2012-30, 2012-33 I.R.B.165
2011-50
Superseded by
Rev. Proc. 2012-36, 2012-39 I.R.B.374
Treasury Decisions:
9752
Corrected by
Ann. 2012-35, 2012-38 I.R.B.356
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2012–1 through 2012–26 is in Internal Revenue Bulletin 2012–26, dated June 25, 2012.
November 5, 2012iii2012–45 I.R.B.

Internal Revenue Service
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ashington,DC20224
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