rr-12-12.pdf

us-irs-revenue-rulings-rr-12-12rr-12-12.pdfGuidance

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Part I

Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments
Issued for Property

(Also Sections 382, 1288)

Rev. Rul. 2012-12

This revenue ruling modifies Rev. Rul. 2012-9, 2012-11 I.R.B. 475, which
provides various prescribed rates for federal income tax purposes for March 2012, to
correct two of the rates.
Table 2 of Rev. Rul. 2012-9 contains short-term, mid-term, and long-term
adjusted applicable federal rates (adjusted AFR) for March 2012 for purposes of section
1288(b) of the Internal Revenue Code. The rate published in Table 2 of Rev. Rul. 2012-
9 as the annual long-term adjusted AFR (3.47 percent) is corrected to be 2.97 percent.
Table 3 of Rev. Rul. 2012-9 sets forth the adjusted federal long-term rate for
March 2012 and the long-term tax-exempt rate described in section 382(f) for March
2012. The rate published in Table 3 of Rev. Rul. 2012-9 as the long-term tax-exempt
rate for ownership changes during March 2012 (3.55 percent) is corrected to be 3.47
percent.

EFFECT ON OTHER REVENUE RULING(S)
Rev. Rul. 2012-9 is modified.
PROSPECTIVE APPLICATION
Under the authority of section 7805(b), the corrected rates will not be applied
adversely with respect to debt instruments issued on or before March 20, 2012, or to
ownership changes that occurred on or before March 20, 2012.
DRAFTING INFORMATION
The principal author of this revenue ruling is Andrea M. Hoffenson of the Office of
Associate Chief Counsel (Financial Institutions & Products). For further information
regarding this revenue ruling, contact Andrea M. Hoffenson at (202) 622-4188 (not a
toll-free call).

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